Epstein Secrets

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

, 2011 Motion to Dismiss is DENIED; and it is further ORDERED that Plaintiffs Jeffrey Epstein and L.S.J., LLC, must join as a party to this action Molyneux Studio and, to that end, must file a Second Amended Complaint within fourteen (14) days of entry of this Order, which shall differ from the First Amended C

existing party Sufi,* to a substantial risk of incurring double, multiple or otherwiee intionsistent obligations because of the interest.° Without Molyneux Studio in the case, the Court would be hard-pressed to accord complete relief among Plaintiffs and Fanelli: Asa party claiming third-party beneficiary stat

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

clli fabricated and installed pursuant to the Purchase Order, as follows: The work executed by Fancclli Paneling following the project designed by Molyneux Studio, and corrections executed March 19 -23 are approved and accepted by the client representative and by Molyneux Studio. Balance on completed work is

ct: Re: stj - cpstcin SEPT 8th Punch list Importance: High For Settlement Purposes Only - Without Prejudice Donna, In addition to the work on what Fancelli refers to as the September 8 punch list, I understand that the following are also to be properly addressed and corrected: The sliding window shutte

s what Fancelli is now referring to as the September 8 punchlist. If that is the case, please confirm that it contains all of the work to be done by Fancelli, so we can formalize an agreement, or whether we can even use it as the punchlist to be included with additional, new work to be agreed upon. Thank

waxed/varnished. EFTA00732332 Thanks. Darren On Sep 30, 2010, at 2:39 PM, Donna Glasgow wrote: Darren, The e-mail below, sent to my client by Molyneux Studio, is what Fancelli is now referring to as the September 8 punchlist. If that is the case, please confirm that it contains all of the work to be done

77 MEMORANDUM TICIENIONIC TELICCOPialna TO: Damn Indyke FROM: Jay Goldberg DATE: March 25, 2010 At the time of your e-mail stating that Mr. Fancelli was not on the Island, you were --- as in so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16

he library building is equipped with a state of the art system to condition the air inside the building. During the installation of the paneling by Fancelli, the exterior doors have been off their hinges and wide open the humid tropical air, and also the windows have been open, allowing humid air to ent

RAN. Swift A. ACCEPTED: DATE: 750 LEXINGTON AVE 5th FLOOR, NEW YORK, NEW YORK 10022 FAX: EFTA00625041 cra,nea PAN ALI NG September 30, 2009 Molyneux Studio 29, East 69th Street 021 Attn: Aurelien Gallet: INVOICE 1098 1 Estimate 065 - D .ipf email 05/09/2009 Work order 8321 Job Reference: St.

PHONIC main:J.6000 TaCCOMIM law via-sools TO: Damn Indyke FROM: Jay Goldberg DATE: March 25, 2010 At the time of your e-mail stating that Mr. Fancelli was not on the Island, you were --- as in so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16

he library building is equipped with a state of the art system to condition the air inside the building. During the installation of the paneling by Fancelli, the exterior doors have been off their hinges and wide open the humid tropical air, and also the windows have been open, allowing humid air to ent

RAN. Swift A: ACCEPTED: DATE: 750 LEXINGTON AVE 5th FLOOR, NEW YORK, NEW YORK 10022 FAX: EFTA00625048 cra,nea PAN ALI NG September 30, 2009 Molyneux Studio 29, East 69th Street avaliali21 Attn: Aurelien Gallet: INVOICE 1098 1 Estimate 065 - D )pf email 05/09/2009 Work order 8321 Job Reference:

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.

12, 2010, we confirm that during our last on site intervention of March 2010 we executed all the expected work listed on the punch list provided by Molyneux Studio, Mr. Epstein's Designer. Since we haven't been informed of any additional work, therefore we cannot give you any confirmation of a "2 days 2 person

on site with Finisher for of process and color approval 1 person 2 days €950 / per Day per Person 1000/0 on order €1,900.00 Supervision from Fancelli for approval and signature 1 person 2 days €1.200.00 / per Day per Person 1000/0 on order €2,400.00 Crew - Expenses 2 person 2 days $380.00

PANELING October 26th 2010 Molyneux Studio Juan Pablo Molyneux 250 Lexington Avenue New York, NY 10022 (212) 628-0097 SUBJECT: SAINT JAMES -DESIGNATED PUNCH LIST & PROPOSED NEW WORK Plea

To: Doug Schoettle[ From: Jeffrey Epstein Sent: Fri 10/9/2009 9:46:43 PM Subject: Re: Office Building Paneling : Molyneux and Fancelli is the floor and waxinf before molyncux or after On Fri, Oct 9, 2009 at 5:45 PM, Jeffrey Epstein <jecvacationgumail.com> wrote: the travel is his

of December depending scheduling by Molyneux and Fancelli to complete the woodwork. Please give your attention to the Fancelli invoice provided by Molyneux Studio, I recommend payment of the deposit so that the work may proceed as quickly as possible. Best Regards, Doug EFTA_R1_00189966 EFTA01818000 ****