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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
EMENT AND RELEASE ("Agreement") is entered into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes hav
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
According to Plaintiffs, Fancelli's agents were on Little St. James a number of times in order to complete the installation? Fancelli's president, Jean Pierre Fancelli ("Mr. Fancelli"), was on St. Thomas and Little St. James in January and March 2010. Plaintiffs allege that Fancelli understood that its constructi
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
. was served with the summons and the FAC at its business address located at 24 East 64th Street, New York, NY 10021, in care of its president, Mr. Jean Pierre Fancelli, through Mr. Christian Barthod who verified to the process server that he worked at Fancelli Paneling, Inc. Defendant never argues that the summons
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
any of their respective joint or several obligations under this Agreement or the Office Design Agreement, and nothing provided herein shall release Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any such Fancelli entity (colle
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
EMENT AND RELEASE ("Agreement") is entered into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes hav
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
EMENT AND RELEASE ("Agreement") is entered into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("JE", and together with LSJ, "Epstein"). WHEREAS, disputes hav
Entities connected to both St. John and Jean Pierre Fancelli

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSONFancelli
PERSONV.I.C.
ORGANIZATIONthe Superior Court of the Virgin Islands
ORGANIZATION
New York
LOCATION
V.I.
LOCATIONDivision of St. Thomas
ORGANIZATION
New York City
LOCATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONthe State of New York
LOCATIONEpstein Releasees
PERSONJuan Pablo Molyneux
PERSONBertrand
PERSONStudio
PERSONthe Settlement Work
ORGANIZATIONthe Fancelli Releasors
ORGANIZATION