EFTA01121352.pdf

ATTORNEY OR PARTY %WHOLLY ATTORNEY (Name, Slate 8ar nwnbw, Andaddress): FOR COURT USE ONLY JONATHAN B. COLE (70460) VINCENT S. GREEN(231046) NEMECEK & COLE 15260 Ventura Blvd., Suite 920 Sherman Oaks, CA 91403 TELEPHONE NO • . TAX NO. (000480. E-MAIL ADORESS (Option's°. ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles STREET ADDRESS: 111 North Hill Street MAILING ADDRESS: CRY AND ZIP COOE:Los Angeles, California 90012 BRANCH NAM£ CENTRAL DISTRICT PLAINTIFF/PETITIONER: SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC DEFENDANT/RESPONDENT: JEFFREY EPSTEIN; an individual; and DOES 1 through 20, inclusive CASE NUMBER: NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL BC502448 TO (insert name of party being served): JEFFREY EPSTEIN NOTICE The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil may subject you Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below incurred in serving a summons (or the party on whose behalf you are being served) to liability for the payment of any expenses on you in any other manner permitted by law. a partnership), or other entity, this If you are being served on behalf of a corporation, an unincorporated association (including of process on behalf of such form must be signed by you in the name of such entity or by a person authorized to receive service you to acknowledge receipt of entity. In all other cases, this form must be signed by you personally or by a person authorized by day you sign the summons. If you return this form to the sender, service of a summons is deemed complete on the acknowledgment of receipt below. Date of mailing: MARCH 12 , 2013 VINCENT S. GREEN (TYPE OR PRINT NAME) (SIGNATURE OF SENDER-MJST NOT BE A PARTY IN THIS CASE) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipt of (to be completed by sender before mailing): 1. A copy of the summons and of the complaint. CASE 2 Other (specify): NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL (To be completed by recipient): Date this form is signed: (TYPE OR PRINT YOUR NAME AND NAME OF ENTITY, IF ANY, (SIGNATURE OF PERSON ACKNOWLEDGING RECEIPT. WITH TITLE IF ON WHOSE BEHALF THIS FORA! IS SIGNED) ACKNOWLEDGMENT IS MADE ON BEHALF OF ANOTHER PERSON OR ENTITY) Pape toll Ca Form &NOW ferMardifty Use NOTICE AND ACKNOWLEDGMENT OF RECEIPT — CIVIL sot dIt)CiYil Pnlajda 415.30, 417.10 Asdidel Court-II ol Callfcenia u ns- POS-015 [Rev. Mowry I, 2005) Cat EFTA01121352  POS-015 ATTOMETORWMCYMTHOUTAT1MRNEY(aentaWBecownemaWm0w): FORCOORTMWOMY JONATHAN B. COLE (70460) VINCENT S. GREEN(231046) NEMECEK & COLE 15260 Ventura Blvd., Suite 920 Sherman Oaks, CA 91403 TELEPHONE NO.: TAX NO. (Optionao. Emsamomsfloptimo: KnowcynmNmo Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles STREET/400RM 111 North Hill Street MAILING ADDRESS: CITY AND ZIP CODE: Los Angeles, California 90012 BRANCH WE: CENTRAL DISTRICT PLAINTIFF)PEITTIONER: SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC DEFENDANT/FtESPONDENT: JEFFREY EPSTEIN; an individual; and DOES 1 through 20, inclusive CASE WINER. NOTICE AND ACKNOWLEDGMENT OF RECEIPT—CIVIL BC502448 TO (insert name ofparty being served): JEFFREY EPSTEIN NOTICE The summons and other documents identified below are being served pursuant to section 415.30 of the California Code of Civil Procedure. Your failure to complete this form and return it within 20 days from the date of mailing shown below may subject you (or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons on you in any other manner permitted by law. If you are being served on behalf of a corporation, an unincorporated association (including a partnership), or other entity, this form must be signed by you in the name of such entity or by a person authorized to receive service of prooess on behalf of such entity. In all other cases, this form must be signed by you personalty or by a person authorized by you to acknowledge receipt of summons. If you return this form to the sender, service of a summons is deemed complete on the day you sign the acknowledgment of receipt below. Date of mailing: MARCH 12 , 2013 VINCENT S. GREEN (TYPE OR PRINT NAVE) (SIGNATURE OF SENDER-MUST NOT BE A PARTY IN THIS CASE) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipt of (to be completed by sender before mailing): 1. A copy of the summons and of the complaint. 2. Other: (specify): NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE (To be completed by recipient): Date this form is signed: (TYPE OR PRINT YOUR NAME AND NAME OF ENTITY. IF ANY. (SIGNATURE OF PERSON AOCNOWLEDGING RECEPT. WITH TITLE IF ON WHOSE BEHALF THIS FORM IS SIGNED) AOCNOWLEDGMENT IS MADE ON BEHALF OF ANOTHER PERSON OR ENTITY) Pe0e1c41 Form Aeopexl Tor lee/WMory UM Cade of Cell Pm:flak Judoal C0IACII of California NOTICE AND ACKNOWLEDGMENT OF RECEIPT - CIVIL St 415.30.417.10 POS-015(Rev. Jenury1.2006] EFTA01121353  SUM-100 SUMMONS FOR COURT USE ONLY (CITACION JUDICIAL) (SOLO PARA USO DE LA CORTE) NOTICE TO DEFENDANT: JEFFREY EPSTEIN; an individual ; (AVISO AL DEMANDADO): and DOES 1 through 20, inclusive EONFOOSIED COPY OfgQINAL ethic, mon.orFILED emArostwa COL.NTY OF LOS ANCELFS MAR 07 2013 YOU ARE BEING SUED BY PLAINTIFF: SITRICK AND COMPANY, a (LO ESTA DEMANDANDO EL DEMANDANTE): division of SITRICIP A.Ctarke,Excc ve 0fficer:Clerk . MUNCH° GROUP, LLC By epwy 1 va NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below. You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtin(o.ca.goviselfhelp). your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the Califomia Legal Services Web site (wvnv.lawhelpcalifomia.org), the California Courts Online Self-Help Center (vnvve.courtinfo.ca.goviselfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The courts lien must be paid before the court will dismiss the case. jAVISOI Lo han demandado. Si no responder dentro de 30 dies, Is code puede decidir en su contra sin escucher su version. Lea la information a continuation Tiene 30 DIAS DE CALENDARIO despues de que le entreguen esta citation y papeles legates pare presenter una respuesta par escrito en esta code y facer que se entregue una copia al demandante. Una carte o one Ilameds teleldnica no lo protegen. Su respuesta poi escrito hens que ester en formato legal conecto si desea que procesen su caso en la code. Es posible que hays un fommlario qua usted puede user pare su respuesta. Puede enoontrar estos formularios de la cote y nes infonnaci0n en el Centro de Ayuda de las Cortes de California (\wnv.sucorte.ca.gov), en la bablioteca de /eyes de su condado o en la code que le quede mos cotta. Si no puede pager /a errata de presentation, pida al secretarto de la code que le de un lormulario de exencien de pago de cuotas. Si no presents su respuesta a tiempo, puede perder el caso poiincumplimiento y la code le padre quitar su avoid°, dinero y bienes sin mos advertencb. Hay otros requisitos regales. Es recomendable que flame a un abogado inmediatamente. Si no conoce a an abogado, puede Ilamar a un servier0 de remision a abogados. Si no puede pager a un abogado, es posible que cumpla con los requisitos pare obtener servicios regales gratuitos de un programa de servicios legates sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services, kvivr.lawhelpcalifomis.org), en el Centro de Ayuda de las Cones de California, (wonv.sucorte.ca.gov) o pomendose en contacto con la cone o el colegio de abogados locales. A VISO: Par ley, la cone bane derecho a reclamar las motes y los costos exentos poiimponer un gravamen sobre cuabuier recuperation de $10,000 0 mes de valor recibida mediante un acuerdo o una concesion de arbitraje en un caw de derecho civil. Tiene que pager el gravamen de la torte antes de que la cone puede desechar el caso. I he name and address of the court is: CASE NUMBER: (El nombre y direcci0n de la code es): (Piers* cki Coco) Los Angeles Superior Court Central District BC5 24 4 111 North Hill Street Los Angeles, California 90012 The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is: (El nombre, la direction y el n0mero de telefono del abogado del demandante, o del demandante ue no lien s: JONATHAN B. COLE ( 7 04 6 0 ) VINCENT S. GREEN (231046) NEMECEK & COLE 1 5 2 6 0 Ventura Blvd. Sherman Oaks, CA 9 1 4 03 Deputy DATE: •Intin A. mow Clerk, by CRISTINAGRIJAIVA (Adjunto) (Fettle) (Secretario) (For proof of service of this summons, use Proof of Service of Summons (form POS-010).) (Pam prueba de entrega de este citation use el formulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED: You are served (SEAL) 1. ET as an individual defendant. 2. ni as the person sued under the fictitious name of (specify): 3. n on behalf of (specify): MAR 07 2013 under: in CCP 416.10 (corporation) ni CCP 416.60 (minor) CCP 416.20 (defunct corporation) El CCP 416.70 (conservatee) CCP 416.40 (association or partnership) n CCP 416.90 (authorized person) other (specify): 4. 1 by personal delivery on (date): Pego1 oil Ern Adopted for Mandatory use SUMMONS nose or Chi Procedure IS 412.20. 455 API081C0j01 of Coithrenta SUM-100 (Roy. Jury 1, 200B] EFTA01121354  1 JONATHAN B. COLE (70460) VINCENT S. GREEN (231046) 2 NEMECEK & COLE APC 3 15260 Ventura Boulevard, Suite 920 CONFOUNIth Psi She 91403 orticiriAL soptiopmcR,ootri.cosrritx Ativitant 4 Tel: Fax: MM. MAR 0 7 2013 5 Attorneys for Plaintiff SITRICK AND COMPANY, John A. Clarke, Exec we Officentlerk a division of SITRICK BRINCKO GROUP, LLC 6 BY - vs 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNT OF LOS ANGELES - CENTRAL DISTRICT 2 .1; 10 O 11 SITRICK AND COMPANY, a division of ) Case No. BC502448 It, 9 6E' 12 SITRICK BRINCKO GROUP, LLC, ) aoxm ) COMPLAINT FOR DAMAGES 13 Plaintiff, ) BASED UPON: ) 03 On 14 VS. ) (1) BREACH OF CONTRACT; ) (2) BREACH OF ORAL CONTRACT; III O R. 15 U tt JEFFREY EPSTEIN, an individual; and ) (3) COMMON COUNTS; 0 16 DOES 1 through 20, inclusive, ) (4) ACCOUNT STATED; Wad= Oyu ) (5) OPEN BOOK ACCOUNT; AND Z <" 17 Defendants. ) (6) QUANTUM MERUIT ) OL t: 18 DEMAND FOR JURY TRIAL 19 20 21 Plaintiff, SITRICK and COMPANY, a division of SITRICK BRINCKO GROUP, LLC 22 ("Plaintiff") complains and alleges as follows: 23 GENERAL ALLEGATIONS 24 1. Plaintiff is and at all times herein mentioned was, a limited liability company 25 organized and existing under and pursuant to the laws of the State of California and 26 doing business in the State of California, with its principal place of business located in 27 28 Los Angeles County. 1 2489003P.i.com COMPLAINT FOR DAMAGES, ETC. EFTA01121355  1 2. Plaintiff is informed and believes, and thereon alleges, that defendant 2 JEFFREY EPSTEIN ("Epstein") is, and at all times relevant hereto was, a citizen of and 3 residing in the State of Florida. 4 3. Epstein has engaged in the necessary minimal contacts with the State of 5 California for this Court to entertain personal jurisdiction, including, but not limited to, 6 7 entering into a contract in California with a California limited liability company, phone calls 8 and emails to Plaintiff in California for strategy and advice, and paying for services 1 9 delivered from California. • 10 4. On or about November 4, 2005, Epstein entered into a written contract •O- 11 It 2? (the "Contract") with Plaintiff to provide advice and public relations services. The 82 12 r.r.1 z Contract provides it may be terminated with 30 days written notice by either party. The n A 13 H5 Contract has never been terminated. A true and correct copy of the contract is attached 03 O LC V) 14 oz,.6 4. 14.§ hereto as Exhibit 1. gi 15 w 16 5. On or about March 11, 2011, Epstein entered an oral contract with Plaintiff <8§ 17 (the "Oral Contract") to provide consulting advice and public relations services concerning 8 al 18 Epstein's relationship with Prince Andrew of England. 19 6. The true names and capacities of Defendants DOES 1 through 20, 20 inclusive, whether individual, corporate, associate, or otherwise, are unknown to Plaintiff 21 22 at this time, who therefore sues said Defendants by such fictitious names, and when the 23 true names and capacities of such Defendants are ascertained, Plaintiff will seek leave of 24 Court to amend this Complaint to insert same. Plaintiff is informed and believes and 25 thereon alleges that each Defendant named as a DOE is responsible for each and every 26 act and obligation hereinafter set forth. 27 7. Plaintiff is informed and believes and thereon alleges that each Defendant 28 named in this Complaint was at all times herein mentioned and now is the agent, servant 2 2489003P.I.com COMPLAINT FOR DAMAGES, ETC. EFTA01121356 1 and employee of the other Defendants herein, and was at all such times acting within the 2 course and scope of said agency and employment and with the consent and permission 3 of each of the other co-Defendants, and each of the Defendants herein ratified each of 4 the acts of each of the other co-Defendants, and each of them. 5 8. The obligation sued upon herein was incurred in and is payable in the 6 7 County of Los Angeles, State of California. 8 9. Said obligation is commercial in nature, not based upon a retail installment 9 sales contract or a conditional sales contract, and not subject to the provisions of Civil 10 Code §§1812.10 and 2984.4. 11 FIRST CAUSE OF ACTION 12 (Breach Of Written Contract as Against Epstein and Does 1 through 20, and Each of Them) 13 10. Plaintiff repeats, realleges and incorporates herein by reference the 14 15 allegations of paragraphs 1 through 4 and 6 through 9, inclusive, as though set forth at 16 length. 17 11. Pursuant to the terms of said Contract, entered into by and between 18 Plaintiff and Epstein on or about November 4, 2005, Plaintiff agreed to provide advice 19 and public relations services to Epstein, and Epstein agreed to pay for these services. 20 12. Plaintiff has sent written statements of account to Epstein listing the 21 22 amount of its indebtedness to the Plaintiff and requesting payment therefore from 23 Epstein. 24 13. On or about July 8, 2011, Epstein breached the Contract by failing to pay 25 Plaintiff for the advice and public relations services rendered. 26 14. Plaintiff has performed all conditions, covenants and promises required on 27 its part to be performed in accordance with the terms and conditions of the Contract 28 except as excused by the breach of Epstein 3 2489003P.twil COMPLAINT FOR DAMAGES, ETC. EFTA01121357  1 15. Pursuant to the terms of said Contract, and as a result of Epstein breach of 2 said Contract, the Plaintiff has been damaged in the sum of $103,517.82, together with 3 interest thereon at the legal rate from the date the obligations were due, and said sum is 4 now due and owing. 5 SECOND CAUSE OF ACTION 6 (Breach of Oral Contract as Against Epstein and Does 1 through 20, and Each of 7 Them) 8 16. Plaintiff repeats, realleges and incorporates herein by reference the 9 allegations of paragraphs 1 through 3 and 5 through 9, inclusive, as though set forth at O 10 length. 11 tig 17. Pursuant to the terms of said Oral Contract, entered into by and between §- 12 z us Plaintiff and Epstein on or about March 11, 2011, Plaintiff agreed to provide advice and C ow 13 C)2g5 public relations services to Epstein, and Epstein agreed to pay for these services. 14 40.8LL 18. Plaintiff has sent written statements of account to Epstein listing the E4 tts 15 n L.T.,Tat, 16 wwm p N m amount of its indebtedness to the Plaintiff and requesting payment therefore from z"ic.E1) 17 Epstein. 00 18 19. On or about July 8, 2011, Epstein breached the Oral Contract by failing to 19 pay Plaintiff for the advice and public relations services rendered. 20 20. Plaintiff has performed all conditions, covenants and promises required on 21 22 its part to be performed in accordance with the terms and conditions of the Oral Contract 23 except as excused by the breach of Epstein. 24 21. Pursuant to the terms of said Oral Contract, and as a result of Epstein 25 breach of said Oral Contract, the Plaintiff has been damaged in the sum of $103,517.82, 26 together with interest thereon at the legal rate from the date the obligations were due, 27 and said sum is now due and owing. 28 4 2489003P.I.com COMPLAINT FOR DAMAGES, ETC. EFTA01121358 1 THIRD CAUSE OF ACTION (Open Book Account For Reasonable Value Of Services Rendered as Against 2 Epstein, and Does 1 through 20, and Each of Them) 3 22. Plaintiff repeats, realleges and incorporates herein by reference the 4 allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein. 5 23. Within the last four years, at Los Angeles County, California, Epstein, 6 7 became indebted to Plaintiff in the sum of $103,517.82 as and for the balance due upon 8 an open book account for advice and public relations services provided by Plaintiff to 9 Epstein based upon the Contract and Oral Contract. Pursuant to the Contract and Oral 10 Contract, payment was promised and agreed by Epstein to be made. Billing records of 11 legal fees and costs incurred by Epstein, including debits and credits, were kept in the 12 regular course of business by Plaintiff and kept in a reasonably permanent form reflecting 13 an open book account in the aggregate reasonable value of $103,517.82. 14 15 24. No part of said sum has been paid, although demand therefore has been 16 made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of 17 $103,517.82 together with interest thereon at the legal rate from the date the obligations 18 were due. 19 FOURTH CAUSE OF ACTION 20 (Open Book Account, For Agreed Value Of Services as Against Epstein, and Does 1 through 20, and Each of Them) 21 22 25. Plaintiff repeats, realleges and incorporates herein by reference the 23 allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein. 24 25 26. Within the last four years, at Los Angeles County, California, Esptein 26 became indebted to Plaintiff for legal services provided by Plaintiff to Epstein at its 27 specific instance on an open book account in the agreed value of $103,517.82. 28 27. No part of said sum has been paid, although demand therefore has been 5 2489003P.1.com COMPLAINT FOR DAMAGES, ETC. EFTA01121359 1 made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of 2 $103,517.82, together with interest thereon at the legal rate from the date the obligations 3 were due. 4 FIFTH CAUSE OF ACTION 5 (Account Stated Against Epstein, and Does 1 through 20, and Each of Them) 6 28. Plaintiff repeats, realleges and incorporates herein by reference the 7 allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein. 8 29. Within the last four years, at Los Angeles County, California, an account 9 was stated by and between Plaintiff and Epstein, wherein and whereby it was agreed that 10 11 Epstein was indebted to Plaintiff in the sum of $103,517.82, which sum Epstein agreed 12 and promised to pay, and that no part of the same has been paid. 13 . 30. No part of said sum has been paid, although demand therefore has been 14 made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of 15 $103,517.82, together with interest thereon at the legal rate from the date the obligations 16 were due. 17 SIXTH CAUSE OF ACTION 18 (Quantum Meruit Against Epstein and Does 1 through 20, and Each of Them) 19 31. Plaintiff repeats, realleges and incorporates herein by reference the 20 allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein. 21 22 32. Between on or about November 2005 through June 2011, Plaintiff 23 performed public relations services on behalf of Epstein for which Epstein promised to 24 pay Plaintiff at its fair and reasonable value. 25 33. Demand for payment for these services has been made by Plaintiff to 26 Epstein, but Plaintiff has not been paid. 27 34. The fair and reasonable value of said services equals not less than 28 $103,517.82 or an amount to be proven at trial. 6 2489003P.1 corn COMPLAINT FOR DAMAGES, ETC. EFTA01121360  1 35. Epstein has failed and refused, and continues to fail and refuse, to pay 2 Plaintiff for said services, leaving a balance immediately due to Plaintiff according to 3 proof, but in no event less than $103,517.82, together with interest thereon at the rate of 4 10% per annum from the date said sum became due. 5 WHEREFORE, Plaintiff prays judgment against Epstein, and Does 1 through 20, 6 7 and each of them, as follows: 8 1. For damages in the sum of $103,517.82, together with interest thereon at 9 the legal rate from the date the obligations were due; 2 1. 10 2. For reasonable attorneys as provided for by the Contract; gg 11 LL13 2. For costs of suit incurred herein; and, 5F), 12 Ngp O 13 3. For such other relief as the Court deems just and proper. Ca) Egl 14 ,a? Dated: March 2013 NEMECEK & COLE Li.1 16 1 15 u • q, • a-cc O[2- 16 te am Z <11 17 By: (imAi-i4- r JO THAN B. COLE VINCENT S. GREEN cc 18 Attorneys for Plaintiff 19 SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC R, 20 21 22 23 24 25 26 27 28 7 2489003P.1.com COMPLAINT FOR DAMAGES, ETC. EFTA01121361  DEMAND FOR JURY TRIAL Plaintiff SITRICK and COMPANY, a division of SITRICK BRINCKO GROUP, LLC, demands a trial by jury on all claims. Dated: March 2013 NEMECEK & COLE By: --//-- JONATHAN B. COLE VINCENT S. GREEN Attorneys for Plaintiff SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC 8 2489003P.1.com COMPLAINT FOR DAMAGES, ETC. EFTA01121362  \ . . EFTA01121363 Facottkr^saar titoympc.l.s.Pdt_. • - SITRICK AND COMPANY INC LCISAMZLIS tfiFT KOS Noronha 4,2005 Roy Black, Esq. Black, StebniekKatispan & Stumpf 201 S. Biscayne /31., /11300 Miami, FL 33131 Dear Roy. 114 later. When accepted by you below oo behalf oflefRey Ermein (the *Client') and accepted by Black. Stebnick, Romspan & Stumpf (*Anomie:1, will prostitute the agreement with respect to the engagement of Sitrick And Company Inc., a California eomontion rSlirlelti as corporate coinmunieations advraot, specialist and non-desimmtcd expert consultant, with =poet to any legal issues Attorney is kindling for Client on the followitig terms and conditions: 1. The MGM and Attorney, effective as of October 21, 2005, have nixed Slott to provide advice and public Malian soviets in COnneCtial with legal isnot it is handling. 2. Shriek will waive its canonry non-refundable retainer of $60,000 us a minimum, mural fec. hi lieu thereof,• Company shall pay &wick a non-rtfialdshic retsina of 530,000 as a minimum, annual fee- Sitrick's lime charges will be billed against the retainer at the hourly rate range of $165 to $650 depending cut the porton performing the. ScritiOng Pgrainbre.timintiassintanl nom is billed at 355.00 per hour. Mini the retainer bas beat applied against time charges, additional time charges in any yar still be billed as incurred and arc payable within twenty days after receipt Muses arc computed to portal-toponal basis for any travel time foe meetings held outside of Sinick's *from Tine is billed by Sitrick in increments of one-quancr of an hour. In addition, we custOnlarily inquest s 'IMAMS fee' if we believe we have Fit:donned services for a client which result in significant benefits to the client beyond those we believe a nomad public relations flan could achieve. Obviousty, we would sit down and discuss any such proposed foe with you if we believe if:swan-need, as such fix would be subject to your approval Please review.our bilk each month upon roocipt. If you have any tiliesnOnSi please feel toe to call However, =less you make some protest to Subtle in writing within twenty days of receipt of the bill, it will be presumed you have no objections to it and amp: to the reasonableness of the bill. 3. The Client shall reimburse Siltick within twenty days of invoice time for any and all out of pocket costs sad espouses matured by Sitrick in connection with its engeganem I NO Carlo P • Si *))• A C.1 SO067.2109 • Pat EFTA01121364 • SMUCE.AND COMPANYINC 444:14W141.1O4.1 November 4, 2605 hereunder, including without limitation, travel eons, production costs, long distance and photocopy charge. and other out-of-pocket costs and expenses. Reimbursable toms are not applied against the teener and will be billed monthly by &trick. 4. Sitrick acknowledges that its savices being provided pursuant to this letter apt-anent an for the benefit of Client and St Attorney. as Clients comet. shall nut be responsible for any feat, costs or expenses haeutred in coon...Mice with Sinick's services. 5. Sitrick And Company's engagement hereunder may be terminated by either party on 30 dims prior written notice. All provisions of this later relating to the payment of fees and expenses and indannifteadon will 4u4Yht any temithation of the engagement by either piny. All the peovisions of this id= contained in paragraphs 4, 5. 6 sod 7 will survive for a period of Iwo years following the date of any 441117114t100 of the engagement by either party. 6. In the event any employee of Shtick, a sissy time is requited or requested to pannipate or provide testimony, dneuannis or other evidence in any anion. arbitration or other proceeding relating, directly or indirectly, to ow engagement. whether or not our engagement has been terminated, the Client shall pay Sitric for the time spent in preparing for and providing such participation or testimony. at Sinick's that standard bilking MILS. end for any costs and expense; including anosneys feu, incurred in connection therewith. 7. • Client agnxs to indemnify and hold harmless Sitrick, its shareholders, officers, directors, employees and agents (each such entity or person bring referred to as al 'Indemnified Person') from and against any and all losses, claims, damages, liabilities, costs and expenses (including, but not limited to, framable attomeis feat) which any Indemnified Person may be subject to or incur in connector, with the service rendered by Sitticl. to Chet and/or Attorney. This ptragraph shall out apply to any such losses, dams, &tinges, liabilities. costs or expenses of any lade:omitted Person that are judiciaDy Cearniotel to have resulted from Shriek's or such other Indemnified Person's gross negligence or willful misconduct. 8. Each of the parties hereto agrees to keep this letter agreement, and the tan and conditions hereof, including billing stalemate and time sheets, aridly confidential, except only as arty be accessary to enforce this letter. MI communications, correspondence, instruments and writings between Sete and Attorney shall be deemed to cantione attorney work-product and otherwise protected by the attorney-client privilege. Each of the parties agrees not to solicit for employment, nor aoploy, any employee of the other during the pending of Shriek's amusement and for a period of two yews themeler. 9. Any ma not paid to Shriek pursuance to this agreement within ten days seen due dull beat interest at the rate of son percent pa mown If action be commenced to enforce any 2 1510 Cria..47 • SO367-2 Kr/ • Ns- EFTA01121365 Spott Koinspap z loySlack.pctf ., • SITRICX AND COMPANY1NC. Lai1.1921.1S•INEVAIR Novemba 4. 2005 provision of this letter agreement, the prevailing pray shall be entitled to reasonable attorney fees. Any conuoverry, chim or dispute relating to this letter agreement shell be resolved by binding arbitration in accordance with the rules of the American Arbitration Association pursuant to an arbitration conducted in Len Angeles County, California. Judgment upon such tutritrntice may be catered in any court having turrsdietion thereof. This letter agreement shall be interpreted and enforced in accordance with the substantive las of the State of CaNecenin applicable to commas mode and to be performed therein. Very truly )ours. Chaim= and Chief &motive Officer Agreed to and accepted this le(„by or ad vt"1 r" 'Attorney" Coansel Cheat By SC-14 !Cy- fti 4v'er •fo. ISht k. Cie; n. r. Kr IC 04, es, 3 C.einury 000.1.111 Vs= 9000.11C9 • EFTA01121366 Scott Korpspan - RoySiack.pdf SiTRICK AND COMPANY INC Alatit • MOOVOIOC November 4.2005 Roy Black, Esq. Stebnick, Komsmm & Stumpf 201 S. Bbxaysto 1:11., /1300 MIA* FL 33131 Re Jeffrey Epstein INVOICE RetsRo' cc for the period beginning: October 21, Retlandabk Expeaseactance $5,000.00 TOTAL DUE ..._...__...__..__.______.___._ S35,000.OO Please wire troisfer funds to: CITY NAT OVAL RAMC min ACCOUNT OF: *MUCK. AND COMPANY ABA ROMTNO NO.: 122 016 066 CREDIT ACCOUNT Nat 112294570 ATTN: DAVE NATHAN Kam wake cluck payshk to: SITRICK AND COMPANY INC. MD Canary Put East, Sum 900 Lob 7 Fed. ID No. 95.4 19873$ 4 EFTA01121367  SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL. CASE (NON-CLASS ACTION) Cue Number THIS FORM IS TO BE SERVED WITH MR SUMMONS AND COMPLAINT BC 5 024t8 on the rause side mum form. Your ease is auigasd for all purposes to the judicial offica indicated below (Local Hide 33(4). There Is additional hilbroatioa DEPT ROOM ASSIGNED JUDGE • • - 'DEPT ROOM ASSIGNED JUDGE Hon. Daniel Buckley 1 534 Hon. Debro Katz Weintraub 47 507 48 506 Hot Michael P.1 Infield 10 631 Hon. Elizabeth . . White . ... , .Allen 12 636 Hon. Deirdre HE 49 509 Hon. Sahara A. Mei= 14 300 Hon. John L. Segal 50 508 Hon. Terry A. Gnat . . . . Hoe. Richard Bruin . 15 307 Hon Abraham!then 51 511 306 Hon. Susan BryaubD•sason 52 510 Hon. Rita Miller 16 17 309. . Hon. Steven J. Kthffield