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

corporations. The affidavit of service of Plaintiff's process server states that he delivered a copy of the Summons and First Amended complaint to "Christian Barthod, co-worker, a person of suitable age and discretion." As noted in the Affidavit of Mr. Christian Barthod, Def. Exhibit B1, he holds no special corp

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

at its offices, 24 East 64th Street, New York, NY on November 29, 2010, by "delivering a true copy of [the Summons and First Amended Complaint] on Christian Barthod, CO-WORKER a person of suitable age and discretion." (emphasis supplied). FAC, Exhibit 1. Plaintiff, in its argument, goes to great lengths to conv

al project - a library - in mind. He seemed vague as to details, so I asked him to send plans. He said he did not have any, but wanted to visit the Fancelli showroom. I set an appointment with him for November 29, 2010 at 5:3015. 4. On November 29, 2010, Charles Oregano called again to make sure that I

siness card. When I went to get it, he took his bag from the chair and placed it on the work table. I handed him my card and he confirmed that I am Christian Barthod. 5. I requested his card, but instead he pulled out a large yellow envelope. He said, "I hope you are not going to be mad, but I have to do this, I