EFTA00313240.pdf

1 2 3 4 5 6 7 8 9 10 I A n 11 w 5ga 12 agt - 13 81/ 14 oFhuo 15 c q 16 17 18 19 20 21 22 23 24 25 26 27 28 JONATHAN B. COLE (70460) DAVID A. MYERS (140181) NEMECEK & COLE A Professional Corporation 15260 Ventura Boulevard, Suite 920 She jforni Tel. / Fax Attorneys for Plaintiff SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT SITRICK AND COMPANY, a division of ) Case No. BC502448 SITRICK BRINCKO GROUP, LLC ) ) BRIEF SUMMARY OF CASE Plaintiff, ) SUPPORTING DEFAULT JUDGMENT ) -vs- ) ) [C.R.C. 3.1800(a)(1)] JEFFREY EPSTEIN, an individual; and DOES) 1 through 20, inclusive, ) ) Defendants. ) ) PARTIES Plaintiff: Sitrick and Company, a division of Sitrick Brincko Group, LLC Defendant: Jeffrey Epstein BRIEF SUMMARY OF THE CASE Plaintiff Sitrick and Company ("Plaintiff) entered into a written contract with defendant Jeffrey Epstein ("Defendant") to provide advice and public relations services (Exhibit A).' These services were sought by the Defendant in order to counteract negative media and public attention regarding alleged improper sexual relations with a minor. Defendant also entered into an oral 'All Exhibits referenced herein are attached to the concurrently filed Declaration of Michael S. Sitrick in Support of the Application for Default Judgment (the "Declaration"). 2489003P.05 Summary CRC3.I800.wpd BRIEF SUMMARY OF THE CASE IN SUPPORT OF DEFAULT JUDGMENT EFTA00313240 1 2 3 4 5 6 7 8 9 A 10 S II ua 12 USE O 13 g • § 9,1 14 d- "- (1g2 (..) .0 15 LI) agf • la 16 17 18 19 20 21 22 23 24 25 26 27 28 contract with Plaintiff to provide consulting advice and public relations services to assist Defendant's attorneys attempting to counteract other negative media attention. This arose from a photograph of Prince Andrew and the Defendant walking in Central Park published in news articles in the United Kingdom and the United States titled, "The Prince and the Pedophile," "Duchess of York Got Loan From Wealthy US Pedophile," "Meet Manhattan's Raunchy New Odd Couple — The Prince and the Pervert." As set forth in Plaintiff's June 8, 2011 invoice (last invoice behind Exhibit B), Plaintiff owed Defendant a total of $103,517.82 for Defendant's professional services. Defendant has never paid what he owes to Plaintiff. Defendants breached both their written and oral contracts with Plaintiff. As a result, Plaintiff is entitled to Judgment against the Defendant in the sum of $103,517.82 plus interest, attorneys fees, and cost of suit. Pursuant to the written contract, Plaintiff's is also entitled to pre judgment interest at the rate of ten percent (10%) through the date of entry of judgment and thereafter until the judgment is satisfied. In addition, because the contract contains a provision for the prevailing party to recover its attorneys fees, Plaintiff is entitled to recover its attorneys' fees in pursuing this matter (Exhibit A, paragraph 9). On March 7, 2013 Plaintiff filed this action in the Los Angeles Superior Court, LASC Case No. BC502448, against Defendant for Breach of Contract, Breach of Oral Contract, Common Counts, Account Stated, Open Book Account and Quantum Meruit. Plaintiff filed a First Amended Complaint filed on April 8, 2013. Alter serving Defendant with the Summons and Complaint, and never receiving any response, Plaintiff filed a Request for Entry of Default. Default was entered by the Clerk of the Court on July 12, 2013. Plaintiff now requests the Court enter a default judgment against the Defendant. The total amount of the Judgment should be 5151.579.78. This includes: • Compensatory damages of $103,517.82 (the amount of the unpaid invoices for services Plaintiffs rendered for Defendant which have never been paid); • Pre-judgment interest of $23,450.01 (the calculation used for determining the total amount of interest is set forth in the Declaration at par. no. 5); • Attorney's fees of $23,797.00; -2- 2489003/245 Summary CR0.1800.wpd BRIEF SUMMARY OF THE CASE IN SUPPORT OF DEFAULT JUDGMENT EFTA00313241 1 • Costs of $814.95. 2 3 Dated: August 71 , 2013 NEMECEK & COLE 5 By: Nc\ J ATHAN . CO[ 6 DAVID A. MYERS Attorneys for Plaintiff 7 SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC 8 9 10 g 11 § 12 LS E 854 13 03,4t.,,Thj 14 O..§ 15 Re- cu r 16 17 g 18 19 20 21 22 23 24 25 26 27 28 -3- 2489003P 05 Summary CRC3 1800 wpd BRIEF SUMMARY OF THE CASE IN SUPPORT OF DEFAULT JUDGMENT EFTA00313242 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 15260 Ventura Blvd., Suite 920, Sherman Oaks, CA 91403. On August 28, 2013, I served the document described as BRIEF SUMMARY OF CASE SUPPORTING DEFAULT JUDGMENT upon the interested parties in this action in sealed envelopes addressed as follows: Jeffrey Epstein 358 El Brillo Way Palm Beach, FL 33480 X_ (By Mail) I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Sherman Oaks, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after day of deposit for mailing contained in affidavit. (By Overnight Delivery) I deposited this document in the box or other facility located at 15260 Ventura Blvd., Suite 920, Sherman Oaks, CA 91403 regularly maintained by Ovemite Express, in an envelope designated by Ovemite Express with delivery fees paid or provided for, addressed to the persons on whom it is to be served, for guaranteed next business day delivery. - (By Facsimile Transmission) I caused the foregoing document to be served by facsimile transmission to each of the interested parties at the facsimile machine telecopy number shown above. - (By Electronic Service (to individual persons)) By electronically transmitting the document(s) listed above to the e-mail address(es) of the person(s) set forth on the attached service list from fkoljan@nemeeek-cole.com. To my knowledge, the transmission was reported as complete and without error. See, California Rules of Court, Rule 2060. (By Personal Service) I served such envelope by hand to the offices of the addressee(s). Executed on August 28, 2013, at Sherman Oaks, California. X (State) 1 declare under penalty of perjury under the laws of the State of California that the above is true and correct. (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. t4Cc_ JUS P. GRAMS EFTA00313243 NEMECEK & COLE 2 3 4 5 6 7 8 9 a 10 11 12 13 14 15 4; 16 17 18 19 20 21 22 23 24 25 26 27 28 JONATHAN B. COLE (70460) DAVID A. MYERS (140181) NEMECEK & COLE A Professional Corporation 15260 Ventura Boulevard, Suite 920 ShermaSiafornial, Tel. / Fax Attorneys for Plaintiff SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT SITRICK AND COMPANY, a division of ) Case No. BC502448 SITRICK BRINCKO GROUP, LLC ) ) DECLARATION OF MICHAEL S. Plaintiff, ) SITRICK IN SUPPORT OF ) APPLICATION FOR DEFAULT -vs- ) JUDGMENT JEFFREY EPSTEIN, an individual; and ) ) [C.C.P. §585(d); C.R.C. §1800(aX2)] DOES 1 through 20, inclusive, ) ) Defendants. ) ) I, Michael S. Sitrick, declare and state as follows: 1. I am the Chairman and CEO of Sitrick and Company ("Plaintiff") in this action. I submit this declaration in support of the accompanying Application for Default Judgment, etc., against Mr. Jeffrey Epstein ("Defendant"). I have personal knowledge of the facts stated herein, and could and would testify competently thereto if sworn as a witness. 2. Sitrick and Company is a strategic communications company focusing on corporate, financial, transactional and crisis communications. On or about November 4, 2005, the Defendant entered into a written contract (the "Contract") with Plaintiff to provide advice and public-relations regarding allegations that Defendant had improper sexual relations with a fourteen-year-old girl whom he hired to perform a massage. The Contract provides that it may be terminated with 30 days written notice by either party. The Contract was never terminated. A true and correct copy of the Contract is attached hereto as Exhibit A. —1- 2489003P.04 Dec! CCP 585.v.pd DECLARATION IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT EFTA00313244 1 3. On or about March 11, 2011, Defendant also entered into an oral contract with 2 Plaintiff (the "Oral Contract") to provide consulting advice and public relations services to assist with 3 his various attorneys to help counteract negative media attention. This arose from a photograph of 4 Prince Andrew and the Defendant walking in Central Park published in news articles in the United 5 Kingdom and the United States titled: "The Prince and the Pedophile," "Duchess of York Got Loan 6 From Wealthy US Pedophile," "Meet Manhattan's Raunchy New Odd Couple — The Prince and the 7 Pervert." 8 4. Plaintiff sent monthly invoices to Defendant showing the amount owed Plaintiff for 9 Defendant's services and requesting payment. True and correct copies of the invoices are attached i 10 hereto as Exhibit B. The amount of the outstanding balance totals $103,517.82 as shown on the June j 11 8, 2011 invoice contained therein. Defendant has failed to pay Plaintiff for these services. Pursuant w p l E 5.i 12 to the terms of said Contract and the Oral Contract, and as a result of Defendant's failure to pay, a g. 113 Plaintiff has been damaged in the sum of $103,517.82, together with interest thereon from the dates C.) i a I 43 ti g 14 the amounts in each invoice began accruing interest. tc/ l i t 15 5. Payment on each invoice was due within twenty (20) days of receipt of each bill tqii A.1 I i 16 (Exhibit A, paragraph 2). The Contract provides that interest began accruing ten (10) days after g 17 payment was due (Exhibit A, paragraph 9). A true and correct copy of the first invoice dated April 7, " r I 18 2011 in the amount of $71,319.07 is attached behind Exhibit B. Interest on that amount began v I 19 accruing on May 7, 2011. A true and correct copy of the second invoice dated May 3, 2011 in the 20 amount of 328,171.25 is attached behind Exhibit B. Interest on that amount began accruing on June 21 2, 2011. A true and correct copy of the third invoice dated June 8, 2011 in the amount of S4,027.50 is 22 attached behind Exhibit B. Interest on that amount between accruing on July 8, 2011. According to 23 the Contract, interest accrues at ten percent per annum (Exhibit A, paragraph 9). As such, accrued 24 interest on the invoices of Exhibit B at 10% based upon when interest on each began to accrue totals 25 S23,450.01 dull August 21, 2013. 26 6. The Contract also provides that the prevailing party in any action to enforce the 27 Contract shall be entitled to recovery of attorneys' fees (Exhibit A, paragraph 9). In seeking to 28 enforce the Contract and the Oral Contract, and related proceedings such as prosecution of this matter, —2- 2489003P.04 Dccl CCP 5131.wpd DECLARATION IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT EFTA00313245 1 2 3 4 5 6 7 8 9 10 cWi g 15 0. 17 18 a 19 20 21 22 23 24 25 26 27 28 Plaintiff has incurred $23,797.00 in attorneys' fees through August 15, 2013. 7. Plaintiff has also incurred costs. Some of these costs include: court filing fee of $435.00 on 3/7/13; service fee of $159.95 on 5/10/13; and service fee of $220.00 on 6/6/13. These costs total $814.95. 8. The total of the above sums, including $103,517.82 (amount owed for professional services), plus $23,450.01 (interest), plus $23,797 in attorneys' fees, plus $814.95 (costs) equals $151,579.78. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this ay of August 2013, at G California. B : A L S TUCK -3- 2489003P.04 Docl CCP 585.wpd DECLARATION IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT EFTA00313246 EXHIBIT "A" EFTA00313247 UsAt.hosiApi5..-Rs@f felt Nevemba a; 2005 SITRICX AND COMPANY INC insAtallrl• roar Roy Black, E . Blxk, Sntnick, Kornspan C Siempf 201 S. Ilia-sync Ell., 01300 Miami, FL 33131 Hoar Roy. This letter, Mtn auspicd by you below a behalf °path Einstein (the "Clean and accepted by Black, Sitbrdelr, Kennon & Srtirnyf ("Attorney". will constimit the agreement with respect to tbe O38agarnot of Sibiek And Compony Inc., a California corporatioo (*Shrieks) as corporate cancounieetiont advisee, spot-Wirt and non-designated avert consultant, with =pea to any kg/ issues Attorney ia handling for Client on the felhiving tams and conditions: The Chan and Money, etkelive as of October 21, 2005, bare rat End Sitridc to provide advice and public Melons undoes la cavitation with kgal inset It Is handling. 2. Shriek will waive its custorntiy nonashincleble retainer of $60.000 id I acmnl inn- In thaw(- ComPaol shall Pal Sinick a noo-rritindablc rather of $30,000 as a minding*, annual few Sitrick's lint charges will be billed naiad the mates. at the hourly rate range of f 16$ to $650 depending on the person pertaining the seethes; paitmeofessiouslarseinstu Saw is billed at $55.00 per hour. When the retainer has been implied against lime charges. additional time dunes la any year will be billed as incurred aid an payable within twiny days after (=ink Charges cue computed on a ponal.topon al bath for any travel time for meetings bad outside of Shriek's offices Time is billed by Sara in increments of cuae-quartor of an hour. In addition, we °Jib:loci/fly request a 'swath fee" if we believe we have performed services for • dicta which result la anathema benefits to the Oka beyond (base we believe a eoroud public relations form could achieve. Obviously, we world dt down and discuss any web proposed fee with you if %tit-limo it la withanted, its such teo would be sobtri en your appirivol plane reviewrth bills cacti month upon receipt If you tarn any questions, please foci free to calk Ilothvek thins you make wont real% to Slbick In writing within twenty dins of receipt of the bilk it will be presumed you barn no objcsliord to it and agree to the reasonableness of the bill. 3. The Client shall reimburse Shriek within twenty dip of Invoice date for any sad ell out of pocket costs and espacts inomed by SIM& fn contwetlas with Its engagement EFTA00313248 Scott Korean' ROyplaclierif SITIO( AND COMPANY INC to necut • ka• November 4, 2005 herterakr, including without limitation towel costs, production costs, long distance end photocopy charges. end other out-afoot-hi cons and expenses. Reindiortabie costs are not applied against the 'chines and will ho billed monthly by Silrick. 4. Saha acknowiodges clot its services being provided snumtant to this ktter siptemClit sit foe the benefit of Client and that Aocenoy, es Climes counsel, dull not be responsible Tor any fent, costs or anon Matted in conned:no with Sartok's saviors. 5. Shtick And Company's cagsgancint hereunder may be termicamd by tithe( pally on 50 don ptiorunitten notion All provisions of this ktta mining to the payment of fat and espartos and itscloomiDcation will tar Nee any terminationOf the engagement by either party, All the provisions of this lotta ocouained In paregrapbs 4, 5, 6 sod 7 will survive for a period of two years following de date of any termination of the topgallant by twat 6. la dee net any employee of Shtick, in my time is requital or =quested to participle or preside tatimony, dnannerits or ether evidence. in any salon. arbitration or other peortmding relating, directly or iodirealy, to ow apt:mast weedia cc not our engagwatat has been et:mimeo:I, die Client sball pay Sibick for the tient man in miming for and providing Pith partiCipatioci or satimany, al Sitrides then Sudan; billing mat, and for any cam end expenses, including anomeys feet, interned in connection 0land& 7. . Chant evens to indemnify and hold hints Shtick, its shateboldas, officers, cheetort, ettiploycc$ and agents faith such entity or pasta being =fared to as en nodernalfkd Person") from sad 2c:ups( any and all tosses, claims, damages, iktlitifitiek eat" end elven= (including. but not limited to, ressonabk attorney's fem)thich any indoentstfirti Puma may be emblem to or WM- la connection with the or nriem rendered by Shtick to Client and/or Attorney. This paragraph shall pit apply to Nay such lotus, Cleans, damage, liabilities, costs or capon:was of my indenudfkd Person Met we Judicially cktortnintd to have ruuttod from Shriek's or sorb other Indemnified Pavon's gross negligatte or willful misconduct 8. Each of the ponies bacto agree to keep this letter agrooment, and the tan sod conditions bereo4 including billing mamma& mid tine shah. saittty confidatnal, ancept only as may be moessary to edam this leder. All conununications, torneepoodersc, instruments sod vaitingt bases Shtick sod Attorney dull be decrood to consthuto attorney week-product sod otherwise protected by ;be toomoyeliteal privilege Pads of the parties ago* not to solicit for anploymeal, not einploy, any employe of the other during the pestling of Sib-lora atgagetrient and for a period of two years thereafter. 9. Any nom not paid to SWIM pursuant to this rorreccorot within too days Meta due dull bear inlehtet at the pleat= Prevent pa aura If action be counnesioed to rotate soy EFTA00313249 tkiAlcomvan:!1?Valacket....____! • T-ill—. "11 SITRI GC AND COMPANY INC ursua. htlf YOM November 4,7005 provision of this letter 'getout:al, the prevailing party shall be entitled to reasonable arlantey fees. Any commytrry, claim or dispute relating to this later agreement shell be resolved by binding nrbitnitIon in accordance with the Mee of du Arrtuieon Arbitretioa Association pursuant to on arbitration conducted in Los Angeles County, California. Judgment upon fax:b arbitration troy be entered in any cowl having jurisdiction thaeof. This knee ogretemeot shall be iota-poled and enforced In wo , ncc with the substantive Eras of the State of California sppllatble to centrals nude nod to be performed therein. Voy 'My yours. Agreed bet idd soxpted this i ty of /ANC ^Ike "Attorney" Quist to akin By SC44 r.„4.„ Sitrick M Ominous sod CMG( !mouthy Oilier • ‘t dAr . P.A. EFTA00313250 Scott 'iSoipspan RoyBlack.p4t Page 41 Normal. 4, 2003 SITRICK AND COMPANY INC. la »CAW • Ite\ailk Roy Black, Esq. Block, Sm.-hoick, Kornspan rk Sivas/ 201 S. facay»131., #1300 Mina. FL 33131 Re Jeffrey Epstein INVOICE Rain« foe 0u period bcg,innimp Ocala 21, 2003.. Peffindeblo Each» sdvanctr—.,— _.$30,000.00 $5,000.00 TOTAL DUE 335 000 00 Ham sac want fluids 10: CITY NATIONAL BANK. • CRBD1T AcCougr OF: SMUCX AND COMPANY ABA BOUTIN° CREMT AOCO0NT N~ ATTN: HAW NATHAN or Platy ern» check paste lo: S1TRICK AND COMPANY INC. EFTA00313251 EXHIBIT "B" EFTA00313252 SITRICK AND COMPANY A Unit of Sitrick Brincko Group, LLC A Subsidiary ol Resources Global Professionals April 07, 2011 Invoice submitted to: Jeffrey Epstein via email: CC: Jay Le owit r il l.<irkland & Ellis LLP 601 Lexington Ave New York, NY 1022-4611 In Reference To: Jeffrey Epstein Professional services and expenses through: 3/26/2011 Professional fees $70,266.00 Expenses * $1,064.07 Amount Current professional fees and expenses $71,319.07 Balance due $71,319.07 *Expenses may reflect charges from a prior period as well as the current period Terms: Due upon presentation Please Remit Payment Wire funds to: Send checks to: SITRICK BRINICKO GROUP, LLC SITRICK BRINCKO GROUP, LLC City l Bank File 1102 ABM/ 1801 W. Olympic Blvd Credit A/C Pasadena, CA Atm.: Dave a an 91109-1102 Federal Tax ID 1840 Cials o rk East, Suite 800, Los iiii1.1)061 Tel Fax EFTA00313253 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 3/26/2011 Professional Summary Page 2 Name Hours Rate Amount MICHAEL S. SITRICK 55.75 895.00 $49,896.25 TAMARA TAYLOR 0.50 550.00 $275.00 THOMAS S. MULLIGAN 11.50 595.00 $6,842.50 TONY KNIGHT 20.00 595.00 $11,900.00 JEAN S. TRINH 6.50 185.00 $1,202.50 LIZA C. NEDELMAN 0.75 185.00 $138.75 Professional Services Hours Amount 3/7/2011 MSS Discussions with Jeffrey and Martin; review various materials; discussion with 5.00 Today Show producer, draft and revise statements; strategy development with team and T. Knight. TK Planning and strategy with MSS; internet research on coverage of the Prince 3.25 Andrew stories; directing efforts of J. Trinh on collecting clips, and review of some of the clips; review of prior records from 2007 and report to MSS; review of V. Roberts police records; confer with J. Trinh. TSM Confer with T. Knight about starting early on Tuesday morning to field calls 1.00 from British media; review media and other background to prepare. JST Discussion with T. Knight re: clip searches. 0.25 3/8/2011 MSS Various discussions and emails with reporters, Jeffrey, Jay Lefkowitz, follow 6.25 up re: same; confer throughout the day with T. Knight and T. Mulligan. TK Early morning follow ups with journalists in the U.K. regarding the Prince 3.75 Andrew story and provide the statement; directing efforts of Sitrick executive T. Mulligan in NY office re follows with UK journalists; planning and strategy with MSS; read and respond to emails from MSS regarding news coverage and his communications with client and attorneys; review of second day coverage and locating The Mail inaccurate story about phone logs. TSM Review media, ind clip from NBCs Today Show; follow up with media, sending statement and fielding interview requests throughout morning from two reporters at Mail on Sunday, two others at Telegraph; confer on same throughout day with T. Knight, MSS. 4.50 JST Research US and UK clips on Epstein and Prince Andrew; email to T. Knight. 1.50 3/9/2011 MSS Review and respond to email throughout the day, phone conferences, work on 7.00 strategy, discussions with Jeffrey, lawyers; review various materials; discussion with defamation attorneys, PR affiliate in London; follow up re: same. 1840 C Part E t, Suite 800, Los n e 067 Tel Fax EFTA00313254 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 3/26/2011 Page 3 Hours 3/9/2011 TK Read and respond to emails from client and attorneys; planning with MSS and 2.00 comments to him on various versions of the statement; continued review of coverage; confer with T. Mulligan. TSM Review Mail story; confer with T. Knight, MSS re: next steps; take interview 1.50 request from J. Swaine, Telegraph, and forward to T. Knight and MSS. 3/10/2011 MSS Review and respond to emails; phone discussions throughout the'day and into 7.25 the night from media, Jeffrey, lawyers, defamation lawyers in US and UK; strategy development. TK Review of coverage; planning with T. Mulligan and discussion of The Daily 2.75 Mail coverage and recent request for answers; briefing MSS and forwarding Daily Mail message to client and attorneys; phone call with A. Wolfe of Newsweek, fact checking, draft fact check questions for MSS and client. TSM Review media; field interview request from London -limes repoprter K. 3.50 Mansey; take call from and exchange follow up email with S. Churcher, investigative reporter for Mail on Sunday, regarding supposed FBI investigation surrounding prominent friends of J. Epstein; discuss request with T. Knight, MSS. JST Research clips on Epstein and Prince Andrew for T. Knight. 1.00 3/11/2011 MSS Review and respond to various emails; draft script for video; strategy 4.75 discussions with T. Taylor and T. Knight. TK Review of coverage and report to MSS; responding to U.K. media calls; review 1.75 strategy memos from MSS. TSM Review media; compile media contacts to date and exchange with T. Knight. 0.50 TT Discuss media strategy, possible video with MSS. 0.50 JST Review coverage on Epstein for bylines; research US and UK media contacts 2.25 for T. Knight; research News of the World story. LCN Assisted J. Trinh on compiling media list per T. Knight 0.75 3/12/2011 MSS Various discussions with Paul Tweed, Jeffrey Epstein; work on strategy; 4.75 review documents and news clips; follow up re: same; review and respond to email. 3/13/2011 MSS Review and respond to email re: Daily Mail, strategy and Fergie; work on letter 4.75 to Telegraph; email to Paul Tweed, Jeffrey; follow up re: same. Amount 1840 Centu t, Suite 800, Los 0067 Tel Fax EFTA00313255 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 3/26/2011 Hours 3/14/2011 MSS Review and respond to email re: Telegraph, Sunday Mail; discussion with 6.75 Mark Bolland in UK; email to and from Paul on letter; review various clips, email to and from Jeffrey; work on media strategy with T. Knight. TK Review of coverage and forwarding key clips to MSS; planning media strategy 1.75 with MSS. JST Research UK and US media contacts for T. Knight 3/15/2011 MSS TK 3/16/2011 MSS 3/17/2011 MSS for Fergie; review materials. TK Review coverage; phone conversation with Kate Mansey of Sunday Times; review of recent Mansey stories; report to MSS. JST 3/18/2011 TSM 3/23/2011 TK 0.50 Discussions and email with Mark Bolland; draft letter to Mail; review and 6.00 respond various emails with Jeffrey; calls to Marty Weinberg and Jay Lefkowitz; work on statement for Fergie; review various materials, work on ongoing strategy, review op-eds and other approaches; strategy discussion T. Knight. Review of media coverage and forward key dips to MSS; strategy meeting 2.50 with MSS; drafting strategy memo proposal and send to MSS. Review and respond to emails including from Paul Tweed. 0.50 Review and respond to email from Paul Tweed, revise suggested statement 1.50 1.50 Research Kate Mansey clips in the Times for T. Knight; research media 0.50 contacts for list. St all from A. Witheridge, Mail on Sunday, re: J. Epstein colleague. 0.50 S. Cowles. Review on going coverage in Miami Business Review and UK print and report 0.75 to MSS. JST Research most recent dips on Prince Andrew and Epstein; email to T. Knight. 0.50 3/24/2011 MSS Respond to email from Jeffrey, draft note on media strategy, calls to Jeffrey 1.25 and Paul Tweed. Total time charges 95.00 $70,255.00 Page 4 Amount 1840 Centu Park East, Suite 800, Los An eles CA 90067 Tel Fax EFTA00313256 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 3/26/2011 Page 5 Summary of out-of-pocket expenses Amount ON-LINE RESEARCH TELEPHONE 873.00 191.07 Total out-of-pocket expenses $1,064.07 1840 Suite 800, Los .611067 Tel Fax EFTA00313257 SITRICK AND COMPANY A Unit of Sitrick Brincko Group, LLC A Subsidiary ol Resources Global Prolessionals May 03, 2011 Invoice submitted to: Jeffrey Epstein via email: CC: Jay Le owl lr t and & Ellis LLP 601 Lexington Ave New York, NY 1022-4611 In Reference To: Jeffrey Epstein Professional services and expenses through: 4/23/2011 Professional fees $23,171.25 Expenses • $5,000.00 Amount Current professional fees and expenses $28,171.25 Previous balance $71,319.07 Balance due $99,490.32 *Expenses may reflect charges from a prior period as well as the current period Terms: Due upon presentation Please Remit Payment Wire funds to: Send checks to: SITRICK BRINCKO GROUP, LLC SITRICK BRINCKO GROUP, LLC City National Bank File 1102 ABA 1801 W. Olympic Blvd Credit °A,MEM Pasadena, CA Attn.: Dave Nathan 91109-1102 Federal Tax IL 1840 Centu Park East, Suite 800. Los An cies. CA 90067 Tel Fax EFTA00313258 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 4/23/2011 Page 2 Professional Summary Name MICHAEL S. SITRICK TONY KNIGHT BRIAN D. GLICKLICH AARON CURTISS Professional Services Hour8 Rate Amount 13.75 895.00 $12,306.25 8.25 595.00 $4,908.75 2.00 550.00 $1,100.00 9.25 525.00 $4,856.25 Hours 3/28/2011 MSS Review, respond and send various emails. 0.75 TK Email to attorneys requesting information, read and respond to emails from 0.50 MSS; respond to client emails. 3/31/2011 MSS Review and respond to emails re: op-eds; review materials/back up 0.75 documents for op-ed. TK Briefing A. Curtiss on op-ed project, marshaling backup documents for 1.00 A.Curtiss; emails with MSS. 4/1/2011 TK Further discussion of strategic approach to op-ed with A. Curtiss; review first 0.50 draft of op-ed. AC Research media coverage and court history of case; draft and edit op-ed 7.00 response; confer with T. Knight re same. 4/3/2011 MSS Discussion with Roy Black. 0.50 4/4/2011 MSS Review Newsweek/Daily Beast article, discussions with reporter, call to editor, 3.75 draft note for Roy Black to review, discussion with T. Knight. TK Multiple phone calls and emails with MSS regarding correction of story posted 2.25 to The Daily Beast review of story, draft correction request; phone calls to reporter A. Wolfe, emails with R. Black and J. Perzcek at Black's office. AC Review and assess DailyBeast article; confer with T. Knight re: changes to 1.00 op-ed. 4/5/2011 MSS Review materials; review and comment on op-ed; email to Paul Tweed. 2.00 TK Op-ed strategy with A. Curtiss. 0.25 AC Confer with T. Knight re: facts of case and status of op-ed. 0.25 1840 Suite 800, Los 1.111067 Tel Fax Amount EFTA00313259 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 4/23/2011 Page 3 Hours 4/6/2011 MSS Review various materials; review and edit op-ed; work on digital strategy; 4.75 review and edit memo on same; discussion with Roy Black. TK Planning and strategy with MSS; conference call with MSS and R. Black; 2.50 review of older Epstein case news clips and revisions to op-ed and further edits to it after MSS edits; review of strategic digital media proposal. BDG Call and email with MSS, draft best practices memo. 2.00 AC Confer with T. Knight re: op-ed; review edits and changes to same. 0.75 4/7/2011 MSS Strategy discussions with T. Knight re: op-ed placement. 0.25 TK Planning and strategy with MSS; discussion of op-ed placement; further review 1.25 of old files for more on Ashley D.: review email from R. Black. AC Confer with T. Knight re: op-ed and plea documents. 0.25 4/19/2011 MSS Email from Roy Black and his partners re: media inquiry; call reporter at Roy's 1.00 request (DBR), participate in interview with reporter and Roy, review and respond to email re: same. Amount Total time charges 33.25 $23,171.25 Summary of out-of-pocket expenses OTHER 5,000.00 Total out-of-pocket expenses $5,000.00 1840 Centu Park East, Suite 800, Los An eles CA 90067 Tel Fax EFTA00313260 SITRICK AND COMPANY A Unit of Sitrick Brincko Group, LLC A Saba Cory of Resources Global Professionals June 08, 2011 Invoice submitted to: Jeffrey Epstein via email: CC: Jay Le °wi l .t ", & Ellis LLP 601 Lexington Ave New York, NY 1022-4611 In Reference To: Jeffrey Epstein Professional services and expenses through: 5/28/2011 Professional fees $4,027.50 Expenses • $0.00 Amount Previous balance $99,490.32 Balance due $103,517.82 *Expenses may reflect charges from a prior period as well as the current period Terms: Due upon presentation Please Remit Payment Wire funds to: Send checks to: SITRICK BRINCKO GROUP, LLC SITRICK BRINCKO GROUP, LLC City N B File 1102 ARAN 1801 W. Olympic Blvd Credit Al Pasadena, CA Attn.: Dave Nathan 91109-1102 Federal Tax ID 1840 Cr ark 8 4 Suite 800, Los 006 Tel Fax EFTA00313261 SITRICK AND COMPANY EPSTEIN, JEFFREY Invoice through: 5/28/2011 Name MICHAEL S. SITRICK Professional Services 4/29/2011 MSS 4/30/2011 MSS Professional Summary Page 2 Howl Rate Amount 4.50 895.00 $4,027.50 Houra Review and respond to email, meeting with Paul Tweed, work on letter from O 2.50 of Y. Review and respond to email from Jeffrey, Paul; work on letter from D-O-Y; 2.00 follow up re: same. Total time charges 3840 Suite 800, Los S67 Tel Fax Amount 4.50 $4,027.50 EFTA00313262 1 2 3 4 5 6 7 8 9 a 10 g 11 ua RI§ 12 gas 81 13 O? di or_ 14 o o_wo 15 w`uc2, 5 cl .a3 16 z ! §:41 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 15260 Ventura Blvd., Suite 920, Sherman Oaks, CA 91403. On August 28, 2013, I served the document described as DECLARATION OF MICHAEL S. SITRICK IN SUPPORT OF APPLICATION FOR DEFAULT JUDGMENT upon the interested parties in this action in sealed envelopes addressed as follows: Jeffrey Epstein 358 El Brillo Way Palm Beach, FL 33480 X (By Mail) I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Sherman Oaks, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after day of deposit for mailing contained in affidavit. (By Overnight Delivery) I deposited this document in the box or other facility located at 15260 Ventura Blvd., Suite 920, Sherman Oaks, CA 91403 regularly maintained by Ovemite Express, in an envelope designated by Ovemite Express with delivery fees paid or provided for, addressed to the persons on whom it is to be served, for guaranteed next business day delivery. (By Facsimile Transmission) I caused the foregoing document to be served by facsimile transmission to each of the interested parties at the facsimile machine telecopy number shown above. (By Electronic Service (to individual persons)) By electronically transmitting the document(s) listed above to the e-mail address(es) of the person(s) set forth on the attached service list from fkoljan@nemecek-cole.com. To my knowledge, the transmission was reported as complete and without error. See, California Rules of Court, Rule 2060. (By Personal Service) I served such envelope by hand to the offices of the addressee(s). Executed on August 28, 2013, at Sherman Oaks, California. X._ (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. JUS -P. GRAMS EFTA00313263