3
Shared Docs
3
Same-Page
6 / 3
Mentions
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
C Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Roth D. Alger, Esq. VI Bar No. 932 PMB 10 Royal Dane Mall #12 St. Thomas, VI 00802 Tel. (340) 626-0787 Fax (866)211-2646 5 EFTA00310027 Case: 3:10-cv-00034-Clold-kM64oknient #* 8-3 Filed: 06/11/
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
OM R4 LARD CCIRDEMNA TEN CASES. VS E THE LOCETb3)4 OF THE LAND INVOLVED. (c) Afloat(' Warty... I US. Ttkptsc ebaréct) Rosh D. Alger. Esq, PUB 10 Royal Dane Mall Sea IL HASS OP JURISDICTION "ark one thm oriyi O1 O2 Osawast 0 3 hard Qarogot Maktit (U.& CetVITTPOSIC Not hazy) us paknaad 044•14•4 0
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,
• Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Roth D. Alger, Esq. VI Bar No. 932 PMB 10 Royal Dane Mall #12 St. Thomas VI 00802 Tel. Fax 5 EFTA00299560 0 2 Us Otatooar Cc&ant Case: 3:10-cv-00034-CVG-RM Document #: 8-1 Filed: 06/11/10 Page
Entities connected to both Fancelli and Royal Dane

Jeffrey Epstein
PERSONDarren Indyke
PERSONJuan Pablo Molyneux
PERSONthe State of New York
LOCATION
U.S. Virgin Islands
LOCATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATION
Saint James
LOCATIONJay Goldberg
PERSONJ.P. Molyneux Studio
PERSONDenise M. Francois
PERSONthe Office Pavilion
ORGANIZATIONBevilacqua Fabric
ORGANIZATIONthe Exhibit B Services
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATIONRosh D. Alger Esquire
PERSONStudio
PERSONAdjudging
LOCATIONthe Territory of the
LOCATIONVI Bar No
ORGANIZATIONPunch List
ORGANIZATION