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EFTA01083960

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DARREN IC INDYKE Darren K. Indyke, PLLC 301 East 66th Street, 10B New York, NY 10065 Telephone: Telecopier: email: September 1, 2011 yantaal i Mr. Nick Lambros Sound X 360 Northwest Highway Barrington, IL 60010 Dear Mr. Lambros: As you know, I represent Jeffrey Epstein and L.S.J., LLC. I am writing in connection with claims they have against you regarding high-end, professional audio-visual equipment and installation services you held yourself out as being able, but failed, to provide. You falsely held yourself out to Mr. Epstein and his representatives as being a knowledgeable and experienced professional provider and installer of the highest quality audio-visual equipment for large-scale, high-end applications. On the basis of your misrepresentations, Mr. Epstein paid to fly you numerous times to his Island in St. Thomas and his New York property to provide professional technical purchasing and installation recommendations for several different sites at those properties. Based on numerous misrepresentations you made to Mr. Epstein and his representatives regarding your knowledge of and experience with particular audio-visual equipment, you persuaded Mr. Epstein to pay you over $135,000 for equipment that you had never previously purchased or installed or with which you had no prior experience. Your installation of this equipment was generally sloppy and unprofessional, and in many instances improper, so that it did not operate as specified. This required costly project delays and return trips to the properties to bring your work into conformity with even minimal standards. Moreover, much of the equipment that you recommended with the highest possible praise performs poorly and has been subsequently discovered to be of substandard and inappropriate quality for its intended high-end application. As a result, several pieces have not even been installed in the multi-million dollar locations for which you recommended them. EFTA01083

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