Epstein Secrets

FLOOR NEW YORK. NY 10177-0077 MEMORANDUM 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

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00605013 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE October 28, 2009 LITTLE ST. JAMES ISLAND JP

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

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00625040 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE LITTLE ST. JAMES ISLAND 6100 RED HOOK QUARTE

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

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00625047 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE LITTLE ST. JAMES ISLAND 6100 RED HOOK QUARTE

ideration Epstein et at vs. Fancelli Paneling, Inc. Case No. ST-I 0-CV443 "Library Cabinetry"). As third party beneficiaries of that contract with Fancelli, Plaintiffs filed suit against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was i

against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was improper and incomplete. Fancelli was served with the Summons and First Amended Complaint on December 3, 2010. On December 30, 2010, Plaintiffs and JP and Molyneux entered into a co

12 EFTA00307589 Memorandum in Support of Plaintiffs' Motion for Reconsideration Epstein et al vs. Fancelli Paneling, Inc. Case No. ST-IO-CV-443 Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J, LLC filed in the District Court of the Virgin Islands, Division of St. Thomas and St. John as

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

action formerly pending in the District Court of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned 4 EFTA00308327 J.P.Molyneux Studio, Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J. LLC. (the "Molyneux Action'), in which Molyncux alleges: [s]ubsequent to the execution o

eux Studio that the short timeline provided by your clients for the delivery to Little St. James of the woodworking materials and tools required for Fancelli to complete its installation was very unrealistic. Mr. Schoettle also advised that Fancelli should schedule its installation on Little St. James fo

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about two important and time-sensitive issues which have arisen in connection wit

ain outstanding. For almost three weeks now, LSJ's representative, Doug Schoettle, has been emailing JP asking for JP to provide a schedule for the Fancelli cabinetmakers to travel to Little Saint James island to complete the installation of the bookcases and paneling in the Office Pavilion as required

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to you in order to prevent what could soon become a breach by your clients of their obligations

wood paneling for the library of the Office Pavilion (the "Library Cabinetry"). Under third party beneficiary status, Plaintiffs filed suit against Fancelli for breach cn EFTA00307562 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein e

ion for reconsideration of this Court's Order entered on May 24, 2011 requiring Plaintiffs to file a Second Amended Complaint adding J. P. Molyneux Studio, Ltd. as a party on the grounds that such a forced joinder will create manifest injustice. For the reasons set forth below, the Plaintiffs' motion for rec