Epstein Secrets

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

NQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island

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.

ntacts with the Territory: That Plaintiffs learned of Fancelli after they engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shalhout, Docket Nos. 12-1076 & 12-1077. EXHIBIT 1 EFTA00602424 AMENDED

stein, et al. 1340 Taameberg St. Thomas, V.L 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.L 00802 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defendant

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shalhout, Docket Nos. 12-1076 & 12-1077. EFTA00614297 AMENDED NOTICE OF M

ein, et al. 1340 Taarneberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defendant

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shaihout, Docket Nos. 12-1076 & 12-1077, recently confirmed for oral argume

tein, et al. 1340 Taameberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.I. 00802-1001 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defe

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,

ach of contract and negligence. Subsequent y, on December 30, 2010, Plaintiffs entered into a "Confidential Agreement" with Juan ablo Molyneux and J.P. Molyneux Studio, Ltd. in which the parties provided one another with g' releases with respect to events relating to the Little St. James Project. In its May 16, 20