Epstein Secrets

06, 1408 (3d Cir. 1991). In its Memorandum Opinion dated May 16, 2011, however, the Court stated: C. The Court Will Not Dismiss the Matter Based on Fancelli's Defense of 3 See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989) See Leuthner v. Blue Cross & Blue Shield of Northeastern Pa., 454 F.3d 120 (3d

acceptance of Fancelli's obligations arising from the Purchase Order. In short, the benefits due Molyneux were accepted and approved by Molyneux. If Fancelli satisfied its obligation to Molyneux under the Purchase Order, then these is no unfulfilled "promised performance" to be enforced by Plaintiffs, as

eux, by Rosh D. Ager, Esq., states under oath that: s. Subsequent to the execution of the Design Services Agreement [between Juan Pablo Molyneux, Molyneux Studio, Ltd. and Jeffrey Epstein and L.S.J., LLC, dated May 15, 2009], Plaintiffs [Molyneux], with the assistance of an internationally-known woodworking crafts

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

d 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 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

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

Case: 3:10-cv-00034-CVG-RM Document #: 8 Filed: 06/11/10 Page 1 of 5 r DISTRICT COURT OP THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Cash No. 3:1 0-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by'and thro

23 (1989). In ordering joinder, this Court has acknowledged that in Molyneux's absence such "complete relief" cannot be accorded the Plaintiffs and Fancelli. In seeking reconsideration, Plaintiffs, not only continue to misstate Rule 19(a)(1), erroneously holding that "[i]f this Court can grant Plaintiff

between Molyneux's filing of the federal action against Epstein April 10, 2010 and Epstein filing the instant action against Fancelli July 30, 2010. Fancelli's reaction and rights would have been part of each side's due diligence during their settlement negotiations. The resulting machinations of private

ersity jurisdiction, 28 U.S.C. § 1331, this Court will not lose subject-matter jurisdiction by requiring the joinder of Mr. Juan Pablo Molyneux and Molyneux Studio, Ltd. Plaintiffs concede that the individual and the entity are subject to service of process. After a review of the matter posed by the existing parties

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

ENT AND RELEASE ("Agreement") is entered into as of this 2 day of December, 2010 (the "Effective Date"), by and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties")