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

n contracted with Molyneux for the architecture and design of the interior and exterior of a separate building on Little Saint James Island known as the Office Pavilion." FAC„ para. 4, p. 2. They also state that Plaintiff L.S.J., LLC, is the owner of Little St. James Island. See Neitzke v. Williams, 490 U.S. 319, 3

st to you. This means that you will not be responsible for any Fancelli Installer expenses including travel, lodging, food, incidentals, etc. After Fancelli finishes the Installation., I will decide if the color of the paneling is adequate for the overall ambiance. If It Is not, I will select color with

Request Riplace bamboo mash at all cabinet dos* with metal mesh In a dark color that will not rust. Status: New metal grilles are not in agreement 'Fancelli has repaired damaged grilles and will provide 8 new framed grilles for future use. 01901 — Punch List — Item #10 ••••••••••••616 • • Damaged bam

rnish and cause to be properly installed and completed at the Office Pavilion by January 2, 2020 all of the items listed on Exhibit hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010, Molyneux agrees that the' aggregate amount to be applied against the Cre

st to you. This means that you will not be responsible for any Fancelli installer expenses Including travel, lodging, food, incidentals; etc. After Fancelli finishes the Installation, I will decide if the color of the paneling is . adequate for the overall ambiance. If it Is not, I will select color with

l refer to Jeffrey Epstein. propose to include all of the following services and items for the $250,000 that we have agreed: The Office/ Library: Fancelli will complete the installation at no cost to you. This means that you will not be responsible for any Fancelli installer expenses Including travel,

ish and cause to be properly installed and completed at the Office Pavilion by January 1, 2010 all of the items listed on Exhibit B hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010. Molyneux agrees that the' aggregate amount to be applied against the Cre

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

f the Project, Plaintiffs contracted with Molyneux to design the interior and exterior of a separate building on Little Saint James Island known as the Office Pavilion. Molyneux contracted with Fancelli Paneling, Inc. ("Fancelli" or "Defendant"), a New York corporation, to custom make the cabinetry, bookshelves, c

: Report 118 Brice, w >, Christian < >, Tom Melnick s< As per message below, we are still on schedule and the Office Pavilion will be ready for Fancelli installers to start on Monday May 18th. Curtis On 5/11/09 8:08 AM, "curtis" <[email protected]> wrote: See attached Bill Rowles weekly report fo

Gordon [mailto: Sent: Tuesday, May 12, 2009 9:01 AM To: JP Molyneux; Fancelli Paneling; 3 Epstein Subject: FW: Report 118 To: P Confirming that the Office Pavilion will be ready for Fenceli Installers to start on the 18th May, 2009 JP can you please confirm accommodation by the end of today. Brice From: curti

Conversation: Report 118 Subject: Re: Report 118 Brice, As per message below, we are still on schedule and the Office Pavilion will be ready for Fancelli installers to start on Monday May 18th. Curtis On 5/11/09 8:08 AM, "curtis" < wrote: See attached Bill Rowles weekly report for construction. W

eevacation@gmai .com From: Brice Gordon Sent: Tue 5/12/2009 1:48:32 PM Subject: FW: Report 118 Title: FW: Report 118 To: JP J Confirming that the Office Pavilion will be ready for Fenceli Installers to start on the 18th May, 2009 JP can you please confirm accommodation by the end of today. Brice From: curti