EFTA00296751.pdf

9100 HAVENSIGHT PHONE (340) 779.2564 PORT OF SALE STE 15.16 FAX (888) 316.9269 KELLERHALS FERGUSON FLETCHER KROBLIN LLP ST. THOMAS, VI 00802 KFFKLAW.COM August 3, 2012 Via E-mail: 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: Attached please find a copy of the following for your records: • 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. Best regards, Nicole Miller Legal Assistant cc: Attachments 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 JURY TRIAL DEMANDED Defendant NOTICE OF ENTRY OF A(N) ORDER TO:GREG J., FERGUSON, &quire NICK LAMBROS, 1351 MULBERRY LK, CARY., IL 60013- VIA CERTIFIED MAIL Esquire Esquire Please take notice that on MARCH 21,2012 Order was entered by this Court in the above-entitled matter. Dated: MARCH 22, 2012 Venetia H. Velazquez Esq. Clerk of t Superior Court By. 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. HON. MICHAE . TON JUDGE OF THE SUPERIOR COURT ATTEST: Venetia H. Velazquez, Esq. OF THE VIRGIN ISLANDS Clerk e Court / / son Court C erk Supervisor /li/ /2- CERTIFIED A TRUE COPY Date: ia II. Velazquez, Esq. of the Court By: Court Clerk EFTA00296754  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, "'a CASE NO. ST-12-CV- 21 ACTION FOR BREACH 01? CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD 14/1? d/b/a SOUND X, cn co JURY TRIAL DEMANDED Defendants. 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] 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 ref I HEREBY CERTIFY that on the _7 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 ) Case No.: ST-12-CV-2I ) Court Date: at Plaintiff v. ) NICK LAMBROS AND AVLC, LIC D/B/A SOUND X ) Defendant 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 600081saved 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. y aSs Executed on: 8950 Route 108, Suite 100 Columbia, MD 21045 S and swom to le,e mo, &notary public, on this 4 5". day of r---14-c-a.a4 — 2012. ‘7•7-114/44.e." My Commission Expires: Notary Public "OFFICIAL SEAL" DEBORAH A. MILLER Notary Public, Stale el Snots My OnarnIssion as Awl 6,2014 ID: 12-047131 1,.<freceet: binkritdraty Boats vs NIS Lit; C d EXHIBIT A EFTA00296759  In Tc District Court of The Virgin Islands Division of St. Thomas & St. John JEFFREY EPSTEIN AND L.S.I., LLC ) Case No.: ST-12-CV-21 ) Court Date: at Plaintiff v. NICK LAMBROS AND AVLC, LLC D/B/A SOUND X Defendant 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 non, 2/- DI) Norman White Due ProcesslISA, Inc. Eama , on: 8950 Route 108, Suite 100 Columbia MD 21045 me, a notary public, on rd day of 2012. My Coonnission Expires: 40 .34,... OFFICAL SEAL JAMES L ICUREK NOTARYPIAUC 4TATE OF II1403 14V COIMISSION EXPIRESIM3/14 11): 12-047071 Client Referent: Mitkillarcy Epsecin in N14 / * 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 ) / Court Datc: at Plaintiff v. NICK LAMBROS AND AVLC, ) Id.0 Dif3/A SOUND X ) ) Defendant ) AFEIDAVEULF PlatiON4J, SER VICE nit I, Norman White, bereby solemnly doclu r lad et Moncton,: of perjury and visor( peacoat kixtw the following document arc true raid do Orur icdge that the contents of o! 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 Lamb documents: Action for Bradt of Contr s-us with the following lin of act and Fraud lc Complaint by then and those pamnatly of thc &alumni Into the hands of and leavin delivering air= and correct copy g with Nick Lunbrat. That the **caption of tees person setua lly 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$3,0 a iNctsto\ Norman IVIsla - /A -Jo( Due PnxoasUSA, Inc. Executod on: 8330 Route SOL Suite 100 Columbia, bib 21005 (800) 221-0414 S and W i: eatme, notarypublk, on 04$ day " sneed -C 1 a 2012. Nay Public MyConaWaaloa&aphct. .40,..4Ce it O4 O,1 - OFFICIALIPAL" DEBORAH A, RtagE Ray Public, Platt( liSt ivi4 Corantist 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- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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 CASE NO ST-12-CV-21 JEFFREY EPSTEIN and L.S.J., LLC, Vs. BREACH OF CONTRACT AND FRAUD ACTION FOR: NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendant 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 Venetia H. Velazquez Esq. Clerk of the Suge or Court By. ILA FR COURT CLERK 11 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, ) ) JURY TRIAL DEMANDED Defendants. ) 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 Venetia H. Vel C k of the Su xc: Christopher Allen• .lin, Esq. STRELLA aFGE 4.? ACTING CURE DEPUTY C X T: LA H. VELAZQU OF THE CO EFTA00296764  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, (-14V.44. .e) CASE NO. ST-12-CV- 21 -vs- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED -71 Defendants. PUNITIVE DAMAGES SOUGHT.r: CO 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 thetitday 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 ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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 CASE NO crig JEFFREY EPSTEIN and L.S.J., LW, Vs. ACTION FOR • BREACH OF CONTRACT AND FRAUD NICK LAMBROS and AVLC, LW d/b/a SOUND X Defendant NOTICE OF DMM ENTRY OF DEFAULT- MAY 1 7 2012 8y 1 TO:CHRISTOPHER KROBLIN, Esquire NICK LAMBROS via certified mail 1351 MULBERRY LANE, CARY. IL 60013 Esquire Esquire Please take notice that on May 11,2012 an Envy of Default Order was entered by this Court in the above-entitled matter. Dated: May 14.2012 Venetia H. Velazquez Esq. Clerk of the Superior Court By 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- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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. VENETIA H. ESQ. OF Dated NAT U , r 2012 AA ATTEST: ACTING CHIEF DEPUTY C RI VENETIA H. h1UEZ, ESQ. CLERK OF CERTIFIED A TR COPY Date: r xc: Christopher Allen Kroblin, Esq. B' ql r or EFTA00296769  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff CASE NO ST-12-CV-2I JEFFREY EPSTBIN and L.SJ., LLC. Vs. ACTION FOR: BREACH OF CONTRACT AND FRAUD NICK LAMBROS and AVLC, LLC d/b/a SOUND X Defendant 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 Venetia H. Velazquez Esq. Clerk of the Su By. COURT CLERK II 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. HON. MICFIAEL C. DUNSTON ATTEST: Venetia H. Velazquez, F..sq. JUDGE OF THE SUPERIOR COURT Clerk of the ourt / / OF THE VIRGIN ISLANDS b. CERTIF1 'fl LIT:: COP? Lori B. yson Date: Court Clerk Supervisor quez, Es. By: (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, CASE NO. ST-12-CV- 21 -vs- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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: Hon. Michael C. Dunston ATTEST: Clerk of the Court By: xc: Christopher Allen Kroblin, Esq. EFTA00296774  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN Plaintiff ) CASE NO. ST-12-CV-0000021 ) ACTION FOR: OF ) CONTRACT ) VS ) NICK LAMBROS ) AVLC, LLC D/EVA SOUND X ) ) 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- ACTION FOR BREACH OF CONTRACT AND NICK LAMBROS and AVLC, LLC FRAUD d/b/a SOUND X, JURY TRIAL DEMANDED Defendants. 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: .. .-7114/ /4. Hon. Mic