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

EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Defendant's Motion to Dismiss on point, to the extend that 5 V.I.C. § 4903(a)(I) & (2)

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

fs are contractually prohibited from suing or initiating, prosecuting, participating in or otherwise pursuing a suit against Molyneux. l A copy of First Amended Complaint filed in J.P. Molynex Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J., LLC filed in the District Court of the Virgin Islands, Div

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

11. Defendant maintains that the Court Granted, in part, its Motion to Dismiss, pursuant to Fed. R. Civ. P. 12(b)0, with dismissal of the existing First Amended Complaint as the appropriate remedy for the relief requested. 12. Defendant acknowledges, however, that the Court may exercise its discretion to join parti