STEPHEN G. RINEHART VIA E-MAIL AND U.S. MAIL Sandra L. Marshall Mana r f ADR rvi resno, TROUTMAN SANDERS June 17, 2012 CONFIDENTIAL TROUTMAN SANDERS LLP Attorneys at Law The Gni Der Sulkies New o Re: 72 147 00218 12 S1M (Sitrick and Company v. Jeffrey Epstein) Dear Ms. Marshall: This firm represents Mr. Jeffrey Epstein. We understand that on or about March 22, 2012 Sitrick and Company ("Sitrick") unilaterally commenced an arbitration against Mr. Epstein (the "Arbitration") before the American Arbitration Association (the "AAA"). As explained below, Sitrick does not have the right to submit this dispute to arbitration, and its demand for arbitration is based on claims relating to work that is far outside the scope of the only arbitration provision that ever existed between the parties. That provision had long been terminated as Sitrick had completed the last of its services that it previously rendered to Mr. Epstein almost six years ago in 2006. Consequently, Sitrick has no basis to force Mr. Epstein into binding arbitration over an entirely new matter as to which no arbitration agreement exists between the parties. Mr. Epstein, therefore, objects to the Arbitration and requests that the Honorable James M. Slater (the "Arbitrator") (i) dismiss it, or, alternatively, (ii) stay the Arbitration unless and until a court of competent jurisdiction rules that it should proceed, without prejudice to Mr. Epstein's right to appeal any such ruling. Submission of this application shall not be construed as Mr. Epstein's participation in, or consent to, the Arbitration, and any and all rights to challenge the jurisdiction of the Arbitrator, or to challenge the Arbitration on any other grounds, are hereby expressly reserved. I. INTRODUCTION Sitrick claims in this Arbitration that Mr. Epstein owes Sitrick money for public relations work that Sitrick allegedly performed for Mr. Epstein in connection with negative press circulated about the latter