DARREN K. INDYKE DARREN K. INDYKE, PLLC 301 East 66th Street, 10B New York, New York 10065 Telephone: (212) 517-2052 Telecopier: (212) 517-7779 email: February 25, 2010 EA_ENSIJaa and First Class Mali Jay Goldberg, Esq. 250 Park Avenue Suite 2020 New York, New York 10177 Re: Agreement for Design Services dated May 15, 2009 ("Design Services Agreement") by and among Juan Pablo Molyneux, Molyneux Studio. Ltd_LS.L. LLC and leffrey Epstein Dear Jay: The characterization in your February 24, 2010 letter of Mr. Epstein's legitimate requests and concerns as unreasonable, unfair and in bad faith is an obvious attempt to create a self-serving and inaccurate record of what has transpired in this matter. Mr. Epstein forewent litigation and made substantial financial concessions to help Mr. Molyneux in a time of financial need. Mr. Epstein did this despite the fact that Mr. Molyneux misrepresented himself to Mr. Epstein (and, as I am sure you are aware, others) as an architect and, in so doing, caused Mr. Epstein to incur approximately $4 Million dollars of fees, costs and expenses, including $500,000 on engineering fees and substantial sums paid to Mr. Molyneux for architectural services never delivered. Mr. Epstein asked only one thing from Mr. Molyneux, and that was to complete one building to Mr. Epstein's reasonable satisfaction by a specific date. That date has since been extended two times in an effort to spare Mr. Molyneux from having to pay Mr. Epstein additional moneys under the Design Services Agreement in the event Mr. Molyneux did not fulfill his obligations timely. In such event, among other things, Mr. Molyneux would be obligated to pay Mr. Epstein an additional $250,000. This is hardly unreasonable, unfair or in bad faith, but rather shows a concerted effort on Mr. Epstein's part to help Mr. Molyneux complete the Office Pavilion without triggering further financial obligations. EFTA00722592