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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
rt 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.P. Molyneux Studio, Ltd., as nominal Defendant, Case No. ST-10-CV-443 (the "Litigation"). 3. Epstein and Fancelli shall keep confidential all communications, discussions,
as to be properly installed on Little Saint James Island, and the staining and finishing were to be completed. 8. Between May 2009 and March 2010, Fancelli proceeded to install the Library Cabinetry on Little St. James Island. As of the date of this Affidavit, however, Fancelli has failed to fully comp
celli holds itself out as skilled in intricate wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork. In fact, Fancelli's website advertises that Fancelli's "[learn of artisans, sculptors and cabinet makers uphold the tradition and carry on the sophisticated art of fi
nd says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epste
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
.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little St. James. Molyneux has offices in New York, New York
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.
nd says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York (-Studio"). 3. In 2005, Jeffrey Epstein ("Epstein")
as to be properly installed on Little Saint James Island, and the staining and finishing were to be completed. 8. Between May 2009 and March 2010, Fancelli proceeded to install the Library Cabinetry on Little St. James Island. As of the date of this Affidavit, however, Fancelli has failed to frilly com
celli holds itself out as skilled in intricate wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork. In fact, Fancelli's website advertises that Fancelli's Itjeam of artisans, sculptors and cabinet makers uphold the tradition and carry on the sophisticated art of fin
nd says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstei
st to you. This means that you will not be responsible for any Fancelli Installer expenses including travel, lodging, food, incidentals, etc. After Fancelli finishes the Installation., I will decide if the color of the paneling is adequate for the overall ambiance. If It Is not, I will select color with
Request Riplace bamboo mash at all cabinet dos* with metal mesh In a dark color that will not rust. Status: New metal grilles are not in agreement 'Fancelli has repaired damaged grilles and will provide 8 new framed grilles for future use. 01901 — Punch List — Item #10 ••••••••••••616 • • Damaged bam
Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by and throu
"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
lli 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. 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-44
"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
lli 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. 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-44
elease Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any Fancelli entity ("collectively, the "Fancelli Group"), from any Claims whatsoever. 6. That paragraph 4(a) of the Confidential Agreement provides: The Epste
cutors and administrators (collectively, the "Epstein Releasors") hereby fully and irrevocably release each of JP [Juan Pablo Molyneux] and Studio [J.P. Molyneux Studio, Ltd.], and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the "Molyneux Releasees"), of and from any
Entities connected to both Fancelli and J.P. Molyneux Studio, Ltd.

Jeffrey Epstein
PERSONDarren Indyke
PERSONJuan Pablo Molyneux
PERSONJean Pierre Fancelli
PERSONDenise Francois
PERSONthe State of New York
LOCATION
U.S. Virgin Islands
LOCATION
St. John
LOCATIONJay Goldberg
PERSON
New York
LOCATIONMolyneux Studio
ORGANIZATIONJ.P. Molyneux Studio
PERSONDenise M. Francois
PERSON
Prince Charles
PERSONFancelli Panelling, Inc.
ORGANIZATIONL.S.J.
ORGANIZATIONStudio
PERSONthe "Library Cabinetry
ORGANIZATION
Russell Simmons
PERSONthe Superior Court of the Virgin Islands
ORGANIZATION