Epstein Secrets

well as M. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle all Disputes and the Lawsuit as provide

"Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island in the United States Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as M.

ther with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island i

e Virgin Islands is an improper venue.'9 It is Fancelli's burden to prove that the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, is an improper venue.50 Under Virgin Islands law, courts (Def. is Mot. to Dismiss 13.) FED. R. CTV. P. I 9(aX I). RESTATEMENT (SECOND) OF CONTRAC

and that venue is improper.' e Court finds that Fancelli conducted business and contracted to supply services or things in 's Territory. Therefore, Fancelli is subject to the Court's jurisdiction. In addition, the Court ds that Plaintiffs have pleaded a sufficient claim for breach of a third-party benefi

Amended Complaint, arguing, among other things, that Plaintiffs' service of process was insufficient that the Court lacks personal jurisdiction over Fancelli; that Plaintiffs do not state a laim for relief; that Plaintiffs have failed to join a necessary party; and that venue is improper.' e Court finds

over a purchase order. The dispute is over Library Cabinetry that is located on Little St. James island in the Judicial District of St. Thomas and St. John. Defendant delivered a product to the Virgin Islands that it incompletely and improperly installed in defective condition in the Virgin Islands. Th

to Mr. Jean Pierre Fancelli. 5 In addition, Defendant specifically informed Plaintiffs' counsel, Darren lndyke, that because of limitations with Mr. Fancelli's ability to communicate in English, Mr. lndyke should communicate with Mr. Fancelli through Mr. Barthod . Pl. Ex. 3 Thus, Mr. Barthod has been pre

Ex. 4. In support of its argument for insufficient service of process, Defendant asserts that the ...Summons and Complaint (sic) were delivered to Fancelli's office in New York on or about November 29, 2010 and left at that location with an unauthorized employee of Fancelli Paneling, Inc." However, Mr.

tudio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J., LLC filed in the District Court of the Virgin Islands, Division of St. Thomas and St. John and docketed as Case No. 3:10.cv-00034 was attached as Exhibit C to the Defendant's Reply to Opposition to Motion to Dismiss the Complaint with Poi

ideration Epstein et at vs. Fancelli Paneling, Inc. Case No. ST-I 0-CV443 "Library Cabinetry"). As third party beneficiaries of that contract with Fancelli, Plaintiffs filed suit against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was i

against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was improper and incomplete. Fancelli was served with the Summons and First Amended Complaint on December 3, 2010. On December 30, 2010, Plaintiffs and JP and Molyneux entered into a co

ell as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle all Disputes and the Lawsuit as provide

"Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island in the United States Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as J.P

ther with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island i

ell as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle all Disputes and the Lawsuit as provide

"Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island in the United States Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as J.P

ther with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes have arisen between Fancelli and Epstein relating to, among other things, the fabrication, finish and installation by Fancelli of certain cabinetry on Little St. James Island i

sputes"); and WHEREAS, the Parties are parties to a lawsuit now pending before the District Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. 3:10-cv-00034 (the "Lawsuit"); and WHEREAS, the parties hereto desire to settle all Disputes and the Lawsuit as provided in this A

se Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any such Fancelli entity (collectively, the "Fancelli Group"), from any Claims whatsoever. (b) JP and Studio and each of their successors, assigns, principals heir