IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF St THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED AFFIDAVIT Denise Francois, after being duly sworn deposes and says: 1. That I am an attorney authorized to practice law in the United States Virgin Islands, and a partner in the law firm of Hodge & Francois, legal counsel of record for the Plaintiffs Jeffrey Epstein and L.S.J., LLC (the "Plaintiffs") in the above-captioned action. 2. That I have personal knowledge of the matters set forth herein. 3. That on December 30, 2010, the Plaintiffs and Juan Pablo Molyneux and J. P. Molyneux Studio, Ltd. ("Molyneux) entered into a confidential Settlement Agreement and Release (the "Confidential Agreement") which, among other things, prohibits Plaintiffs from disclosing certain facts about the Confidential Agi ment or its terms without first giving five (5) business days advance written notice to Molyneux of Plaintiffs' intent to disclose facts about the Confidential Agreement. 4. That I have been provided with a true and correct copy of the Confidential Agreement duly executed by the Plaintiffs and Molyneux. EFTA00307575