4
Shared Docs
4
Same-Page
8 / 4
Mentions
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
r it to, and properly install it on, Little Saint James Island in the United States Virgin Islands. It was the clear understanding and agreement of Studio and Fancelli when they contracted that all of their contracts with respect to the Library Cabinetry were for the benefit of Epstein and LSJ and that the Library
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
r it to, and properly install it on, Little Saint James Island in the United States Virgin Islands. It was the clear understanding and agreement of Studio and Fancelli when they contracted that all of their contracts with respect to the Library Cabinetry were for the benefit of Epstein and LSJ and that the Library
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.
miss under Rule 12(b)(6). In addition, the attached Affidavit of Juan Pablo Molyneux confirms that "It was the clear understanding and agreement of Studio and Fancelli when they contracted that all of their contracts with respect to the Library Cabinetry were for the benefit of Epstein and LSJ and that the Library
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
r it to, and properly install it on, Little Saint James Island in the United States Virgin Islands. It was the clear understanding and agreement of Studio and Fancelli when they contracted that all of their contracts with respect to the Library Cabinetry were for the benefit of Epstein and LSJ and that the Library
Entities connected to both Fancelli and Studio and Fancelli

Jeffrey Epstein
PERSONthe State of New York
LOCATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATION
New York
LOCATIONFancelli Panelling, Inc.
ORGANIZATIONthe "Library Cabinetry
ORGANIZATION
Little Saint James Island
LOCATIONSaint James'
PERSONEl Escorial
LOCATIONStudio's
ORGANIZATION