August 3, 2012

August 3, 2012 Via E-mail: KELLERHALS FERGUSON FLETCHER KROBLIN LLP Jeffrey Epstein ATTN: Darren Indyke St. Thomas, VI RE: Jeffrey Epstein, et al v. Nick Lambros, et al. Civil No. 2012/ 21 Our File No. 00324.030.001 Dear Mr. Indyke: 9100 HAVENSIGHT PORT OF SALE STE 15.16 ST. THOMAS, VI 00802 Attached please find a copy of the following for your records: PHONE (340) 779.2564 FAX (888) 316.9269 KFFKLAW.COM • Order dated March 20, 2012; • Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X and proposed Order; • Entry of Default dated May 1, 2012; • Notice of Filing dated May 7, 2012; • Entry of Default dated May 11, 2012; • Order dated May 30, 2012; • Motion for Extension of Time by Which to File Plaintiffs' Motion for Default Judgment and proposed Order; • Order dated June 22, 2012; • Plaintiffs' Motion for Default Judgment and proposed Judgment; and • Order dated July 24, 2012. Please contact the undersigned if you have any questions. cc: Attachments Best regards, Nicole Miller Legal Assistant TAMPA I US VIRGIN ISLANDS NEW YORK EFTA00296751 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff CASE NO. ST-I2-CV-2I JEFFREY EPSTEIN and LLC Vs. t ACTION FOR: NICK LAMBROS and ACLC, LW, d/b/a SOUND X Defendant JURY TRIAL DEMANDED NOTICE OF ENTRY OF A(N) ORDER TO:GREG J., FERGUSON, Please take notice that on &quire NICK LAMBROS, 1351 MULBERRY LK, CARY., IL 60013- VIA CERTIFIED MAIL Esquire Esquire MARCH 21,2012 entered by this Court in the above-entitled matter. Dated: MARCH 22, 2012 By. Order was Venetia H. Velazquez Esq. Clerk of t Superior Court CA . CLARKE Court Clerk II D03211.301 EFTA00296752 IN THE SUPERIOR COURT THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) ) Plaintiffs, ) CASE NO. ST-12-CV-21 ) v. ) ) NICK LAMBROS and ACLC, LLC, d/b/a SOUND X, ) ) Defendants. ) ) ORDER On March 14, 2012, Defendant Nick Lambros sent correspondence to the Court acknowledging service of the summons on March 10, 2012, "requesting an extension for my court appearance and response", and representing "1 will need some time to retain legal representation." The correspondence does not specify the length of extension requested nor how much time will be required to obtain representation. On March 16, 2012, Plaintiffs opposed the request for extension, characterizing it as an attempt to cause delay, arguing the request is premature, and confirming that service was accomplished on March 10, 2012. Because Defendant Lambros was served outside the Virgin Islands, he has thirty (30) days from the date of service to respond to the Complaint, or until April 9, 2012. Ordinarily, that should provide sufficient time for Defendant to obtain counsel and have counsel answer. Ilowever, given that this case is in its infancy, given that it may take some time for newly retained counsel in the Virgin Islands to become familiar with the facts of this matter in order to properly respond to the allegations of the Complaint, and given that extensions of time to respond to complaints are EFTA00296753 Epstein, et al., v. Lambros, et al. Case No. ST-12-CV-21 Order, March 20, 2012 Page 2 of 2 routinely agreed to by counsel in this jurisdiction as a professional courtesy, a brief extension of time will not prejudice Plaintiffs. Moreover, no proof of service on Defendant ACLC, LLC, has yet been filed. Because that entity operates under an assumed name, ACLC will have to be represented by counsel in this action should it be served. In the absence of proof of service upon Defendant ACLC, a brief extension of time for Defendant Lambros to respond to the Complaint will not cause meaningful delay in these proceedings. Consequently, it is ORDERED that the time for Defendant Nick Lambros to have an attorney enter an appearance on his behalf and to move, answer, or otherwise respond to the Complaint is extended to April 23, 2012; and it is ORDERED that a copy of this Order shall be served on Defendant Nick Lambros, 1351 Mulberry Ln., Cary, IL 60013, by certified mail, return receipt, and a copy shall be directed to counsel for Plaintiff. DATED: March 20, 2012. ATTEST: Venetia H. Velazquez, Esq. Clerk e Court / / son Court C erk Supervisor /li/ /2-HON. MICHAE . TON JUDGE OF THE SUPERIOR COURT OF THE VIRGIN ISLANDS Date: By: Court Clerk CERTIFIED A TRUE COPY ia II. Velazquez, Esq. of the Court EFTA00296754 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. CASE NO. ST-12-CV- 21 ACTION FOR BREACH 01? CONTRACT AND FRAUD 1/41? cn co JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT MOTION FOR ENTRY OF DEFAULT AS TO NICK LAMBROS & RENEWED MOTION FOR ENTRY OF DEFAULT AS TO AVLC _LLC d/b/a SOUND X COME NOW Plaintiffs, JEFFREY EPSTEIN and L.S.J., LLC, by and through their undersigned counsel, KELLERHALS FERGUSON LLP, and hereby move, pursuant to Federal Rule of Civil Procedure 55(a), for the entry of default as to Defendants Nick Lambros and AVLC, LLC d/b/a Sound X. The basis for said Motion is as follows: 1. On January 17, 2012, Plaintiffs filed their Complaint in the above captioned lawsuit against Nick Lambros and AVLC, LLC d/b/a Sound X. Service on AVLC, LLC 2. AVLC, LLC is, upon information and belief, a Limited Liability Company organized under the laws of Illinois and has two listed resident agents, Susan L. Dawson and Ron Goldstein. 3. As a precaution Plaintiffs served both listed resident agents with a summons and copy of the Complaint. 4. Service on Susan L. Dawson was accomplished on February 17, 2012 at 1:20 p.m. [EXHIBIT A] "'a EFTA00296755 Epstein v. Lambros Civil No. 2012-cv-21 Motion & Renewed Motion for Entry of Default Page 2 5. Service on Ron Goldstein was accomplished on February 20, 2012 at 3:45 p.m. [EXHIBIT B] 6. As indicated on the Affidavits of Corporate Service attached as Exhibits A & B, both Dawson and Goldstein stated that they had the legal authority to accept service of process on behalf of AVLC, LLC. 7. To date, AVLC, LLC has failed to appear or otherwise defend this matter. 8. On March 20, 2012, Plaintiffs moved for the entry of default against AVLC, LW. That Motion is still pending before the Court and is renewed by way of the present Motion. Service on Nick Lambros 9. On March 10, 2012, Nick Lambros was personally served with a summons and complaint by process server Norman White in Illinois, whose Affidavit of Personal Service is attached hereto. [EXHIBIT C] 10. On March 14, 2012, Nick Lambros sent a letter to the Court requesting additional time to retain legal representation. 11. Over opposition of the Plaintiffs, this honorable Court granted Mr. Lambros's request for an extension of time to respond to the Complaint of up to and including April 23, 2012. 12. To date, no counsel has appeared on behalf of Nick Lambros and he has failed to respond to Plaintiffs' Complaint or otherwise defend this matter, despite the affidavit of service filed with the Court and, as pointed out by the Court in its Order dated March 20, 2012, despite Nick Lambros's own admission with regard to service. EFTA00296756 Epstein v. Lambros Civil No. 2012-cv-21 Motion & Renewed Motion for Entry of Default Page 3 Federal Rule of Civil Procedure 55(a) states that "When a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party's default." The entry of default is appropriate here because service of process was accomplished on AVLC, LLC on February 17, 2012 and again on February 20, 2012. To date, Plaintiffs have received no responsive pleading from AVLC, LLC. Regarding Nick Lambros, he was served on March 10, 2012. Thereafter, Mr. Lambros was granted an extension of time of up to and until April 23, 2012 to respond to Plaintiffs' Complaint. Mr. Lambros failed to respond within the time ordered by the Court, and he failed to request any additional time to do so. Therefore, Plaintiffs respectfully request an order entering the Defendants into default. WHEREFORE, an entry of default as to both Defendants is requested. Dated May 1, 2012 RISTO HER ALLEN KROB IN ESQ. VI Bar Association No. 966 KELLERHALS FERGUSON LLP 9100 Havensight Port of Sale, Suite 15-16 St. Thomas, USVI 00802 Telephone; Facsimile: Email: EFTA00296757 Epstein v. Lambros Civil No. 2012-cv-21 Motion & Renewed Motion for Entry of Default Page 4 CERTIFICATE OF SERVICE ef I HEREBY CERTIFY that on the _7r day of May, 2012, I caused a true and exact copy of the foregoing Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X to be served via first class mail, postage prepaid, upon: Nick Lambros 1351 Mulberry In. Cary, IL 60013 EFTA00296758 In Tc District Court of The Virgin Islands Division of St. Thomas & St. John JEFFREY EPSTEIN AND LSJ., LLC Plaintiff v. NICK LAMBROS AND AVLC, LIC D/B/A SOUND X Defendant ) Case No.: ST-12-CV-2I ) Court Date: at ) ) AFFIDAVIT OF CORPORATE SERVICg That]. Norman White, hereby solemnly declare oaks the penalties of pajury and upon personal knowledge that the contents of the following document arc true and do affirm I am a comp:tad person over 18 years of age and nonparty to this action. That on NI:may 17, 2012 at 1:7O PM at 2775 Aktonm%in Rd #250 RaOing Meadows IL 60008 1 saved AVLC, LLC dlb/a Sound X with the following IS of documents: Action for Breach of Contract and Proud & Complaint by then and there personally delivering a true and correct copy of the documents into the hands of and leaving with Susan L. Dawson, whose Title is 5. Registercd Agent. That Susan L. Dawaon stated height had the authority to accept as the Legal Representative for the above listed pawn or entity. That the description of Ore person actually saved is as follows: Gender: Female Race/Slcin: white Hair Deep bloode/brown Glasses: No Age: 48 Might: 571 Weight; 140 That the fee for this service is 5129.90 Norman White Due ProcessUSA. Inc. 8950 Route 108, Suite 100 Columbia, MD 21045 yaSs Executed on: S and swom to le,e mo, &notary public, on this 45". day of r---14-c-a.a4 — 2012. ‘7•7-114/44.e." Notary Public My Commission Expires: "OFFICIAL SEAL" DEBORAH A. MILLER Notary Public, Stale el Snots My OnarnIssion as Awl 6,2014 ID: 12-047131 EXHIBIT A 1,.<freceet: binkritdraty Boats vs NIS Lit; C d EFTA00296759 In Tc District Court of The Virgin Islands Division of St. Thomas & St. John JEFFREY EPSTEIN AND L.S.I., LLC Plaintiff v. NICK LAMBROS AND AVLC, LLC D/B/A SOUND X Defendant ) Case No.: ST-12-CV-21 ) Court Date: at AFFIDAVIT OF CORPORATE SERVICE That I, Norman White, hereby solemnly declare under the penalties of perjury and upon personal knowledge that the contents of the following document are true and do affirm I am a competent person over 18 years of ago and not a party to this action. That on February 20, 2012 at 3:45 PM at 718 Frontage Rd 8103 Northfield IL 60093 I served AVLC, II.0 dMa Sound X with the following list of documents: Action for Breach of Contract and Feud k Complaint by then and there personally delivering a true and correct copy of the documents into the hands of and leaving with Ron Colston, whose Title is 6. Authorized Agent for Service of Process. That Ron Golstein stated he/she bad the authority to accept as the Legal Representative for the above listed person or entity. That the description of the person actually served is as (alloy's: Gender: Male Race/Skin: white Glasser No Age: 45 Height ST Weight: 150 That the foe for this service is $189.90 11): 12-047071 non, Norman White Due ProcesslISA, Inc. 8950 Route 108, Suite 100 Columbia MD 21045 me, a notary public, on rd day of My Coonnission Expires: 40.34,... OFFICAL SEAL JAMES L ICUREK NOTARYPIAUC 4TATE OF II1403 14V COIMISSION EXPIRESIM3/14 2/- DI) Eama, on: 2012. Client Referent: Mitkillarcy Epsecin in N1/4* lambro4, ct at EXHIBIT 1 8 EFTA00296760 In re District Court of The Virgin Islands Division of St. Thomas Cc St. John JEFFREY EPSIEL's/ AND L.S.J., Case No.: ST-12-CV-21 ) Plaintiff / Court Datc: at v. ) NICK LAMBROS AND AVLC, Id.0 Dif3/A SOUND X ) ) Defendant ) AFEIDAVEULF PlatiON4J, SERVICE nit I, Norman White, bereby solemnly doclur lad et Moncton,: of perjury and visor( peacoat kixtwicdge that the contents of the following document arc true raid do Oruro! am a oompetent pawn ova 18 ran of age and nonparty to this action. That on Match 10.2012 at 6:15 Phi a/ 1351 MtzPsertylat Cary /L 60013 1st-eyedNick Lambs-us with the following lin of documents: Action for Bradt of Contract and Fraud lc Complaint by then and those pamnatly delivering air= and correct copy of thc &alumni Into the hands of and leaving with Nick Lunbrat. That the **caption of tees person setually saved It as follow,; Gender: Male Race/Skin: white Rafr. brown Glasses: No Ate: 36 Height 6T W.W.I' 200 That the foc fee this soviet is $10$3,0 aiNctsto\ - /A -Jo( Norman IVIsla Due PnxoasUSA, Inc. Executod on: 8330 Route SOL Suite 100 Columbia, bib 21005 (800) 221-0414 S and Wi :eat me, notarypublk, on 04$ day "sneed -C1 a 2012. Nay Public MyConaWaaloa&aphct. .40,..4Ce it O4O,1 -OFFICIALIPAL" DEBORAH A, RtagE Ray Public, Platt( liStivi4Corantist Tat ID:11447563 Client Ise (acme: hilimanttsv rotas n With tsontm,cc et EXHIBIT Col EFTA00296761 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF St THOMAS & St JOHN ** ***** ********************* JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 -VS- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT ORDER BEFORE THE COURT is Plaintiffs' Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X. Having considered the Motion and being otherwise advised in the premise, the Court will grant the relief requested. Accordingly, it is hereby: ORDERED that Defendants Nick Lambros and AVLC, LLC d/b/a Sound X are entered into default. Dated: EFTA00296762 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff JEFFREY EPSTEIN and L.S.J., LLC, Vs. NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendant CASE NO ST-12-CV-21 ACTION FOR: BREACH OF CONTRACT AND FRAUD NOTICE OF ENTRY OF DEFAULT TO:CHRISTOPHER KROBLIN, Esquire NICK LAMBROS via certified mail Esquire Esquire Please take notice that on MAY I, 2012 ENTRY OF DEFAULT Order was entered by this Court in the above-entitled matter. Dated: May 1, 2012 By.Venetia H. Velazquez Esq. Clerk of the Suge or Court COURT CLERK 11 ILA FR EFTA00296763 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS • '`, DIVISION OF ST. THOMAS. & ST. JOHN - • ***************************** JEFFREY EPSTEIN and ) ) Plaintiffs, ) ) ) CASE NO. ST-12-CV- 21 -vs- ) ACTION FOR ) BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC ) FRAUD d/b/a SOUND X, ) ) Defendants. ) JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT EMT OF DEFAULT BEFORE THE COURT is Plaintiffs' Motion for Entry of Default as to AVLC, LLC d/b/a Sound X. Having considered the Motion and being otherwise advised in the premise, the Court will grant the relief requested. Accordingly, it is hereby ORDERED that Defendant AVLC, LLC d/b/a Sound X is entered into default. Dated: MAY 1, 2012 xc: Christopher Allen• .lin, Esq. T: LA H. VELAZQU OF THE CO Venetia H. Vel C k of the Su STRELLA aFGE ACTING CURE DEPUTY C X 4.? EFTA00296764 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. CASE NO. ST-12-CV- 21 ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED -71 PUNITIVE DAMAGES SOUGHT .r: CO (-14V.44..e) NOTICE OF FILING PLEASE TAKE NOTICE that the Plaintiffs, Jeffrey Epstein and L.S.J., LLC, by and through their undersigned counsel, KELLERHALS FERGUSON, LLP, hereby file the attached revised proposed order in regards to their Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X. Dated May 7, 2012 CHRISTOPHER ALLEN KROBLIN, ESQ. VI Bar Association No. 966 KELLERHALS FERGUSON LLP 9100 Havensight Port of Sale, Suite 15-16 St. Thomas. USVI 00802 Telephone: Facsimile: Email: 003.2q. 301 EFTA00296765 Epstein v. Lambros Civil No. 2012-cv-21 Notice of Filing Page 2 CERTIFICATE OF SERVICE I hereby certify that on the titday of May, 2012, a true copy of the foregoing Notice of Filing was transmitted by U.S. mail, postage prepaid to: Nick Lambros 1351 Mulberry Ln. Cary, IL 60013 -744).e.m EFTA00296766 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT ORDER BEFORE THE COURT is Plaintiffs' Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X. Having considered the Motion and having already entered AVLC, LLC into default by separate Order, the Court will grant the relief requested as to Nick Lambros. Accordingly, it is hereby ORDERED that Defendant Nick Lambros is entered into default. Dated xc: Christopher Allen Krohn!), Esq. EFTA00296767 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff JEFFREY EPSTEIN and L.S.J., LW, Vs. NICK LAMBROS and AVLC, LW d/b/a SOUND X Defendant CASE NO crig ACTION FOR • BREACH OF CONTRACT AND FRAUD NOTICE OF DMM ENTRY OF DEFAULT- MAY 1 7 2012 TO:CHRISTOPHER KROBLIN, Esquire Esquire Esquire Please take notice that on May 11,2012 8y 1 NICK LAMBROS via certified mail 1351 MULBERRY LANE, CARY. IL 60013 an Envy of Default Order was entered by this Court in the above-entitled matter. Dated: May 14.2012 By Venetia H. Velazquez Esq. Clerk of the Superior Court COURT CLERK II nn g2LI Zni EFTA00296768 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 -VS- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT BITER OF DEFAULT BEFORE THE COURT is Plaintiffs' Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X. Having considered the Motion and having already entered AVLC, LLC into default by separate Order, the Court will grant the relief requested as to Nick Lambros. Accordingly, it is hereby ORDERED that Defendant Nick Lambros is entered into default. Dated NAT Ur, 2012 ATTEST: VENETIA H. h1UEZ, ESQ. CLERK OF xc: Christopher Allen Kroblin, Esq. VENETIA H. OF ESQ. ACTING CHIEF DEPUTY C RI CERTIFIED A TR COPY Date: r B' ql r or AA EFTA00296769 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff JEFFREY EPSTBIN and L.SJ., LLC. Vs. NICK LAMBROS and AVLC, LLC d/b/a SOUND X Defendant CASE NO ST-12-CV-2I ACTION FOR: BREACH OF CONTRACT AND FRAUD NOTICE OF ENTRY OF ORDER TO:CHRISTOPHER KROBLIN. Esquire Esquire Esquire Please take notice that on MAY 30.2012 AN Order was entered by this Court in the above-entitled matter. Dated: JUNE I, 2012 By.Venetia H. Velazquez Esq. COURT CLERK II Clerk of the Su EFTA00296770 IN THE SUPERIOR COURT THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOI-IN JEFFREY EPSTEIN and L.S.J., LLC, ) ) Plaintiffs, ) CASE NO. ST-12-CV-21 ) v. ) ) NICK LAMBROS and AVLC, LLC, d/b/a SOUND X, ) ) Defendants. ) ) ORDER The Clerk of the Court having entered default on behalf of Plaintiff against Defendant AVLC on May 1, 2012, and against Defendant Lambros on May 1, 2012, and neither Defendant having responded to the Complaint, it is ORDERED that by June 22, 2012, Plaintiff shall either (1) submit a motion for entry of default judgment against Defendants, (2) advise the Court of the reason the filing of such a motion would be premature or otherwise inappropriate, or (3) take other appropriate steps to move this case forward; and it is ORDERED that a copy of this Order shall be directed to counsel for Plaintiff. Dated: May 30, 2012. ATTEST: Venetia H. Velazquez, F..sq. Clerk of the ourt / / b . Lori B. yson Court Clerk Supervisor HON. MICFIAEL C. DUNSTON JUDGE OF THE SUPERIOR COURT OF THE VIRGIN ISLANDS Date: By: CERTIF1 'fl LIT:: COP? quez, Es. (Ming nork EFTA00296771 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN *************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. CASE NO. ST-12-CV- 21 ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT MOTION FOR EXTENSION OF TIME BY WHICH TO FILE PLAINTIFFS' MOTION FOR DEFAULT JUDGMENT COME NOW Plaintiffs, JEFFREY EPSTEIN and L.S.J., LLC, by and through their undersigned counsel, KELLERHALS FERGUSON FLETCHER KROBLIN LLP, and hereby move for an extension of time by which to file their Motion for Default Judgment. The ground for said request is that although entered on May 30, 2012, the undersigned's office did not receive this Court's Order requiring the filing of a Plaintiffs' Motion for Default Judgment until June 14, 2012. As the filing deadline is June 22, 2012, Plaintiffs need additional time by which to prepare their motion. Moreover, the Complaint seeks damages for work done in the Virgin Islands and New York and the supporting documentation for those damages is located in various locations. Plaintiffs have been gathering their evidence but owing to travel and vacation schedules of staff, Plaintiffs have been unable to finish gathering all their documents for counsel's review and inclusion in a motion for default judgment. 603,2q.3oi EFTA00296772 Epstein, et at v. Lanthres, Mal. Civil No. 2012-cv-2 I Motion for Extension of Time Page 2 Plaintiffs believe they will need an additional thirty (30) days to complete their discovery of documents supporting their claims for damages. Accordingly, an extension of time of thirty (30) days or until July 23, 2012 is requested. WHEREFORE, Plaintiffs request an extension of time of thirty (30) days or, up to and including July 23, 2012, by which to file their motion for default judgment. Respectfully, Dated: June 20 2012 ERIKA A. L E HALS, ESQ. CHRISTOPHER ALLEN KROBLIN, ESQ. VI Bar Nos. 849 and 966 KELLERHALS FERGUSON FLETCHER KROBLIN LLP 9100 Havensight Port of Sale, Suite 15-16 St. Thomas USVI 00802 Telephone: Facsimile: Email: EFTA00296773 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ******************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 -VS- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT ORDER BEFORE THE COURT is Plaintiffs' Motion for Extension of Time by Which to File Plaintiffs' Motion for Default Judgment. Having considered the Motion, the Court will grant the relief requested. Accordingly, it is hereby: ORDERED that Plaintiffs shall have up to and including July 23, 2012 by which to file a motion for default judgment. Dated: ATTEST: Clerk of the Court By: xc: Christopher Allen Kroblin, Esq. Hon. Michael C. Dunston EFTA00296774 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN VS NICK LAMBROS AVLC, LLC D/EVA SOUND X Plaintiff ) ) CASE NO. ST-12-CV-0000021 ) ACTION FOR: OF ) CONTRACT ) ) ) ) Defendant NOTICE OF ENTRY OF ORDER TO: CHRISTOPHER ALLEN KROBLIN, ESQUIRE Please take notice that on June 22, 2012 a(n) ORDER dated June 22, 2012 was entered by the Clerk in the above-entitled matter. Dated: June 22, 2012 LORI TYSON COURT CLERK SUPERVISOR 6032)-1. so) EFTA00296775 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ******************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 -VS- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT ORDER BEFORE THE COURT is Plaintiffs' Motion for Extension of Time by Which to File Plaintiffs' Motion for Default Judgment. Having considered the Motion, the Court will grant the relief requested. Accordingly, it is hereby: ORDERED that Plaintiffs shall have up to and including July 23, 2012 by which to file a motion for default judgment. Dated: ...--711/4/4. xc: Christopher Allen Kroblin, Esq. Hon. Michael C. Dunston CERTIFIED A -rRuE COPY Date: me 23, 112-iVenetia H. Velazquez, Esq. Court By: Ccurt EFTA00296776 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ***************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. 4•4 s7b CrhylA, Cd CASE NO. ST-12-CV- 21 ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT • PLAINTIFFS' MOTION FOR DEFAULT JUDGMENT COME NOW Plaintiffs, JEFFREY EPSTEIN and LLC, by and through their undersigned counsel, KELLERHALS FERGUSON FLETCHER KROBLIN LLP, and hereby move for the entry of Default Judgment against the Defendants Nick Lambros and AVLC, LLC d/b/a Sound X. (collectively "Lambros"). I. FACTUAL SUPPORT FOR DEFAULT JUDGMENT In support of their Motion for Default Judgment, Plaintiffs submit the attached affidavits of Darren K. Indyke and Richard Kahn. As set forth in those affidavits, in or about December, 2010, based upon representations made by Nick Lambros over the phone to Jeffrey Epstein in Ncw York and the Virgin Islands as to Nick Lambros's and Sound X's extensive knowledge and experience in the selection, purchasing and installation of state-of-the-art audio-visual equipment for large-scale, high-end, luxury venues, Plaintiffs hired Nick Lambros and AVLC, LLC d/b/a Sound X (collectively hereinafter referred to as "Lambros") to recommend, select, purchase and install high quality, state-of-the-aft audio-visual equipment for installation at multiple locations in a large-scale, multi-structure, multi-million dollar residence on Little Saint James Island EFTA00296777 Epstein, et al. v. Lambros, et al. Case No. ST-12-CV-21 Plaintiffs' Motion for Default Judgment Page 2 located in the U. S. Virgin Islands, as well as a luxury townhouse in New York City. Lambros provided Plaintiffs with a Sound X Project Summary proposal dated December 4, 2010 for a project total of $181,241.80 and accompanying proposals for each individual project. Based upon representations made by Lambros, Plaintiffs paid Lambros One Hundred Thirty-Five Thousand Nine Hundred Thirty-One Dollars and Thirty-Five Cents ($135,931.35) by wire transfer on December 7, 2010 to provide to Plaintiffs equipment of make and models that Nick Lambros represented that Lambros had sold and installed several times previously and with which Nick Lambros represented that Lambros was entirely familiar. Based upon representations made by Lambros, Plaintiffs paid to fly Nick Lambros numerous times to Plaintiff.? properties on Little Saint James Island and in New York City to provide technical advice, recommendations, assistance and installation services for what was represented by Nick Lambros to be state-of-the-art audio-visual equipment, but was in fact substandard equipment that was unfit for its intended purposes. After installation began, it became apparent that Lambros was unfamiliar with the equipment Lambros sold to Plaintiffs and that he had no experience with the installation of the same. Moreover, the equipment sold was not state-of-the-art as Plaintiffs had requested. Lambros admitted as much in an e-mail to Epstein sent January 21, 2011. Plaintiffs incurred numerous expenses in remedying Lambros's defective work. Plaintiffs also incurred expenses in paying for Lambros to come to the Virgin Islands as well as John Bransky (who assisted Lambros) in an attempt to fix the problems cause by Lambros. Plaintiffs incurred project oversight costs in having to rectify the problems caused by Lambros's failure to install proper equipment. Lambros knew he was not qualified to select and install the equipment the Plaintiffs EFTA00296778 Epstein, et al. v. Lambros, et al. Case No. ST-I2-CV-21 Plaintiffs' Motion for Default Judgment Page 3 required. He nevertheless misrepresented that he could select and install the equipment required by Plaintiffs and he intended the Plaintiffs to rely on his statements. The damages caused by Lambros were caused by his intentional misrepresentations and/or gross negligence. As a result, Plaintiffs suffered significant economic harm as detailed above and significant delay in obtaining the sound systems for which they had originally contracted. They, to date, have not obtained the state-of-the-art sound system for which they originally contracted. 11. DAMAGES SOUGHT Federal Rule of Civil Procedure 55 allows this Court to enter default judgment against a party entered into default. Here, both defendants have been entered into default. Therefore, based on the attached affidavits and their accompanying authenticated documents, Plaintiffs seek damages as follows: A. Cost of replacement equipment and re-installation of projector in the amount of $15,689.98. )3. Cost of replacement equipment from Full Compass Systems in the amount of $9,746.06. C. Cost to hire James McNeil to install replacement equipment in the amount of $1,314.00. D. Cost of Audio Video Salon charges for services related to replacement of equipment installed by Lambros in the amount of $700.00. E. Labor, equipment, and travel expenses in the amount of $135,931.35 paid for by Plaintiffs to Lambros for equipment and installation of state-of-the-art sound systems, EFTA00296779 Epstein, et al. v. Lambros, et al. Case No. ST-12-CV-21 Plaintiff? Motion for Default Judgment Page 4 which never ultimately worked as required and could never work as the equipment supplied is not state-of-the-art sound equipment. F. Additional travel costs and expenses related to attempts to fix the sound systems in the amount of $5,419.17. G. Additional costs in labor resulting from having to fix the problems cause by Lambros's gross negligence in the amount of $27,200.00. Accordingly, Plaintiffs seek actual contractual and consequential damages in the amount of $196,000.56. In addition, Plaintiffs seek punitive damages of 50% of the total actual damages ($98,000.28) as a result of Lambros's gross negligence and intentional false misrepresentations regarding his ability to deliver a suitable sound system product as required. WHEREFORE Plaintiffs request a total award of damages in the amount of $294,000.84 plus prejudgment and post judgment interest, and all other damages that are just and proper. Respectfully, Dated: July ;5, 2012 CHRISTOPHER ALLEN OBLIN, ESQ. VI Bar Association No. 966 KELLERHALS FERGUSON FLETCHER KROBLIN LLP 9100 Havensight Port of Sale, Suite 15-16 St. Thomas Telephone; Facsin • Email: EFTA00296780 Jul.23.2012 03:20 PM PAGE. 2/ 5 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LW, Plaintiffs, CASE NO. ST-12-CV- 21 -VS- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants.ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT AFFIDAVIT IN SUPPORT OF DEFAULT JUDGMENT I, Darren K. Indyke, being first duly sworn, depose and state as follows: 1. I am a resident of the State of New Jersey and I am of legal age and competent to make and execute this affidavit based on my personal knowledge and also based on my personal knowledge of the business records of L.S.J., LLC and Jeffrey Epstein (collectively "Plaintiffs"). 2. In or about December, 2010, based upon representations made by Nick Lambros over the phone to Epstein in New York and the Virgin Islands as to Nick Ltunrbos's and Sound X's extensive knowledge and experience in the selection, purchasing and installation of state of the art audio-visual equipment for large-scale, high-end, luxury venues, Plaintiffs hired Nick Lambros and AVLC, LLC d/b/a Sound X (collectively hereinafter referred to as "Lambros") to recommend, select, purchase and install high quality, state-of-the-art audio-visual equipment for installation at multiple locations in a large-scale, multi-structure, multi-million dollar residence on Little Saint James Island located in the U. S. Virgin Islands, as well as a luxury townhouse in New York City. 3. I,ambros provided Plaintiffs with a Sound X Project Summary proposal dated December 4, 2010 for a project total of $181,241.80 and accompanying proposals for each individual project. 4. Based upon representations made by Lambros, Plaintiffs paid Lambros over one Hundred Thirty Five Thousand Dollars to provide to Plaintiffs equipment of make and models that Nick Lambros represented that Lambros had sold and installed several times previously and with which Nick Lambros represented that Lambros was entirely familiar. 5. Based upon representations made by Lambros, Plaintiffs paid to fly Nick Lambros numerous times to Plaintiffs' properties on Little Saint James Island and in New York City to provide technical advice, recommendations, assistance and installation services for what was EFTA00296781 Ju1.23.2012 03:21 PM PAGE. 3/ 5 Epstein & L.S.J., LLC. v. Lambros & AVLC, LLC Civil No. 12 - 21 Affidavit Page 2 represented by Nick Lambros to be state of the art audio-visual equipment, but was in fact substandard equipment that was unfit for its intended purposes. 6. After installation began, it became apparent that Lambros was unfamiliar with the equipment Lambros sold to Plaintiffs and that he had no experience with the installation of the same. Lambros admitted as much in an e-mail to Epstein sent January 21, 2011. 7. Plaintiffs incurred numerous expenses in remedying Lambros's defective work, Plaintiffs also incurred expenses in paying for Lambros to come to the Virgin Islands as well as John Bransky (who assisted Lambros) in an attempt to fix the problems cause by Lambros. Plaintiffs incurred project oversight costs in having to rectify the problems caused by Lambros's failure to install proper equipment. 8. Lambros knew he was not qualified to select and install the equipment the Plaintiffs required. He nevertheless misrepresented that he could select and install the equipment required by Plaintiffs and he intended the Plaintiffs to rely on his statements. 9. The damages caused by Lambros were caused by his intentional misrepresentations and/or gross negligence. 10. As a result Plaintiffs suffered significant economic harm as detailed above and significant delay in obtaining the sound systems for which they had originally contracted. FURTHER SAYETH AFFIANT NOT, Darren K. Indyke SUBSCRIBED AND SWORN before me on this the 23 day of July, 2012. HARRY t, BELLER Notary Public, Sure of NowYodc No. 010E48&3924 Qualified in Rockland County Commission Expires Feb. 17.204 EFTA00296782 Ju1.23.2012 03:21 PM PAGE. 4/ 5 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J.,1LLC, Plaintiffs, CASE NO. ST-12-CV- 21 -Vs- NICK I,AMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FRAUD JURY TRIAL DEMANDED PUNITIVE DAMAGES SOUGHT AFFIDAVIT IN SUPPORT OF DEFAULT JUDGMENT I, Richard Kahn, being first duly sworn, depose and state as follows: I, I am a resident of the State of New York and I am of legal age and competent to make and execute this affidavit based on my personal knowledge and also based on my personal knowledge of the business records of L.S.I., LLC and Jeffrey Epstein (collectively "Plaintiffs"). Plaintiffs maintain records that consist of data compilations and other entries made at or near the time of the events by, or from information transmitted by, a person with knowledge. These records are kept in the regular course of Plaintiffs' regularly conducted business activities. It is also the regular practice of Plaintiffs to make the memoranda, reports, records, and data compilations from which I base my information in this affidavit. I am one of the custodians of those records. I am currently serving as Accountant to Plaintiffs. 2. Plaintiffs hired Nick Lambros and AVLC, LLC MA Sound X (collectively hereinafter referred to as "Lambros") to recommend, select, purchase and install high quality, state-of-the-art audio-visual equipment for installation at multiple locations in a large-scale, multi-structure, multi-million dollar residence on Little Saint James Island located in the U. S. Virgin islands, as well as a luxury townhouse in New York City. 3. Lambros provided Plaintiffs with a Sound X Project Summary proposal dated December 4, 2010 for project total of $181,241.80 and accompanying proposals for each individual project. A true and accurate copy of the e-mail chain including the proposals is attached hereto. [EXHIBIT A] 4. Plaintiffs paid Lambros over one Hundred Thirty Five Thousand Dollars to provide to Plaintiffs services. A true and accurate Internal summary of Plaintiffs' showing a wire transfer made on December 7, 2010 in the amount of $135,931.35 is attached hereto. [EXHIBIT B] EFTA00296783 Ju1.23.2012 03:21 PM PAGE. 5/ 5 Epstein & L.S.J., LLC. v. Lambros &AVLC, LIG Civil No. 12 - 21 Affidavit Page 2 5. Plaintiffs paid to fly Nick Lambros numerous times to Plaintiffs' properties on Little Saint James Island and in New York City to provide services. 6. Lambros sent Epstein an e-mail to Epstein regarding his work on January 21, 2011, a true and accurate copy of which is attached hereto. [EXHIBIT C] 7. On March 6, 2012, Richard Barnett sent Epstein an e-mail regarding a projector which failed to function at Epstein's residence in New York. A true and accurate copy of that e- mail is attached here to. [EXHIBIT D] 8. On July 17, 2012, Cutting-Edge Systems, Inc. submitted a proposal for replacing the projector installed by Lambros in the amount of $15,689.98. A true and accurate copy of that proposal is attached hereto. [EXHIBIT IL] 9. On September 23, 2011. Plaintiffs purchased replacement equipment, to replace equipment provided and installed by Lambros, in the amount of $9,746.06 from Full Compass Systems. True and accurate documents maintained by Plaintiffs related to that purchase are attached hereto. [EXHIBIT F] 10. In November, 2011, Plaintiffs hired James MacNeil to install replacement equipment for the equipment installed by Lambros and to correct the defective installation done by Lambros. MacNeil's services cost Plaintiffs S1,314.00. A true and accurate copy of the invoice and the record of payment of the same is attached hereto. [EXHIBIT G] 11. On or about December 2, 2011, Audio Video Salon charged Plaintiffs $700.00 for services related to the replacement of the equipment installed by Lambros. A true and accurate copy of Plaintiff's records regarding this expense is attached hereto. [EXHIBIT H] 12. In addition to the foregoing expenses, Plaintiff's incurred expenses in paying for Lambros to come to the Virgin Islands as well as John Bransky (who assisted Lambros) in an attempt to fix the problems cause by Lambros. Plaintiffs incurred project oversight costs in having to rectify the problems caused by Lambros's fail install pro r9quipment. A true and accurate summary of those additional expenses and is attached h [EXHIBIT I] FURTHER SAYETI I AFFIANT NOT. Richard Kahn SUBSCRIBED AND SWORN before me on this the 23 day of July, 201 Notafy PubicARR SueLLER Notary Public of Now York .No. 010ES/353024 Commission Expires Fob. 17.20Qualified in flocicland County. 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