Epstein Secrets

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.

HEREBY CERTIFY THAT that I caused a true and correct copy of the foregoing Plaintiff's Opposition to Defendant's Motion to Dismiss to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this 11'" day of February, 2011

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

y of the foregoing MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED ON MAY 24, 2011, to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this Is day of tin rI•P ,

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

ERTIFICATE OF SERVICE I HEREBY CERTIFY THAT that I caused a true and correct copy of the foregoing Motion for Enlargement of Time to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, V 00804 and upon by fust class U. S. Mail, nostage nrenaid on this 30 day of , 20

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

, 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 Fancelli Paneling, Inc. P.O. Box 310, E.G.S. (14A None Gade) St. Thomas, VI 00804-031

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

uire 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 Defendant Fancelli Paneling, Inc. P.O. Box 310, E.G.S. (14A Norre Gade) St. Thomas, V PHONE:

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,

ird party I Plaintiffs Jeffrey Epstein and L.S.J., LLC are represented by Denise Francois, Esq. Defendant Fancelli P eling, Inc., is represented by Treston E. Moore, Esq. 2 For a complete recitation of the factual and procedural history in this matter see this Court's May 1 2011 Memorandum Opinion. Epstein v.

hich was in excess $780,000, plus additional expenses incurred to correct the defects in the Library Cabinetry, the loss of use of the funds paid to Fancelli through Molyneux; and the loss of time and effort of the Plaintiffs' staff, and the expenditure of funds, in the attempt to obtain Fancelli's perfo

, I hereby certify that I caused the foregoing Plaintiffs' Rule 26(a) Initial Disclosure Statement to be served via U.S. Mail, postage prepaid upon Treston E. Moore, Esquire, Moore, Dodson & Russell, P.C. at P.O. Box 310, St. Thomas, VI 00804-0310. 11-nate.htlik Anna Iti cttl3 6 EFTA00309169

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

ue and correct copy of the foregoing MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR ECONSIDERATION OF ORDER ENTERED MAY 24, 2011 to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this r day of -1t.t , 201