Erika Kellerhals KELLERHALS FERGUSON FLETCHER KROBLIN LLP October 25, 2012 Ms. Margarita A. Greenidge-Benjamin Director of Applications U.S. Virgin Islands Economic Development Authority 5055 Norm Gade St. Thomas, VI 00802 Re: Southern Trust Co., Inc. Dear Ms. Benjamin: 9100 HAVENSIGHT PORT OF SALE SUITE 15-16 ST. THOMAS. VI 00802 FAX 8811.11 KFFKLAW.COM In response to your letter of October 17, 2012, please find attached the following information that is intended to supplement the Southern Trust Company, Inc. ("STC") application for benefits from the Economic Development Commission ("EDC"): • The Truth Statement and Release Authorization, a copy of which was previously provided to the EDC. • A bank reference letter for Mr. Jeffrey E. Epstein, a copy of which was previously provided to the EDC. • A revised management-training plan that details the use of the $10,000 per annum budget. Please note that the budget of $10,000 has been incorporated into the revised five-year projection under the line item "Training". • Revised five-year projection with assumptions. • Breakdown of local versus non-local purchases for capital investment. • Executed Form 8821 STC will provide all full-time employees with life insurance in the amount of $50,000. In addition, STC will comply with the provisions of Section 5 of Act No. 7301. Finally, I have been in contact with Mr. Randleman and Ms. Nugent-Hill regarding the submission of Mr. Epstein's tax returns. As discussed with Mr. Randleman, we will make copies of Mr. Epstein's tax returns available for inspection at your convenience in our offices. In addition, I will forward a completed set of Mr. Epstein's tax returns in a sealed envelope to Mr. Handleman with the understanding that these documents will be treated as confidential under the provisions of Title 3, section 881 and shall not be released by the EDC unless otherwise ordered by a court or by the lawful custodian of the records. TAMP