Epstein Secrets

ications, discussions, information or materials in any papers served or filed in the Litigation or in any other litigation. 4. Each of Epstein and Fancelli acknowledges that, unless otherwise decided in the course of the Meeting and accepted in writing by both parties, (a) the only thing which can be m

ncelli Paneling, Inc. ("Fancelli"), with respect to the communications, discussions, information and materials that may be exchanged by Epstein and Fancelli in front of their respective attorneys during the meeting to take place between them on Monday, December 3, 2012, at 11:00AM at the offices of Mait

d Fancelli are participating in the Meeting for purposes of engaging in settlement discussions in connection with ongoing litigation taking place in the Superior Court of the United States Virgin Islands in the case of Jeffrey Epstein and L.S.J., LLC, as Plaintiffs, v. Fancelli Paneling, Inc., as Defendant, and J.

ated to conduct purposely directed at the forum state. Id. Defendant maintains that this Court lacks specific jurisdiction over it as well, because Fancelli does not have sufficient minimum contacts with the Virgin Islands to support the exercise of jurisdiction consistent with due process. See Int'l Sho

e and as may be developed through discovery. The reservation of rights was just that. V. CONCLUSION Plaintiffs Amended Complaint against Defendant Fancelli must be dismissed, with prejudice, for all, or any of the foregoing reasons. WHEREFORE, Defendant respectfully requests this Honorable Court to gr

intiffs' pleading, the First Amended Complaint does not provide any reference to the statutory underpinnings for the subject matter jurisdiction of the Superior Court, 4 V.I.C.§ 76, nor should it be Defendant's responsibility to select Plaintiffs' best weapon in this regard for any response. Subject matter jurisdi

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.

aintiffs FAC and the exhibits attached thereto. 2. Plaintiffs Have Filed Their Lawsuit in the Proper Venue: The St. Thomas and St. John Division of the Superior Court. Defendant also suggests that this case be dismissed because the venue is improper. "To survive a motion to dismiss for improper venue, the plainti

racted with Fancelli Paneling to install furniture and other paneling in the residence's I brary cabinetry. Upon discovering various deficiencies in Fancelli's work, Plaintiffs, as third party I Plaintiffs Jeffrey Epstein and L.S.J., LLC are represented by Denise Francois, Esq. Defendant Fancelli P eling,

f among the existing parties." 7 Superior Court Rule 7 states that "the practice and procedure in the Superior Court shall be governed by Rules of the Superior Court and, to the extent not inconsistent therewith, by the Rules of the District Cowl, the Ocderal Rules of Civil Procedure, the Federal Rules of Crimina