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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
reement are valid and enforceable; and d. Awarding such other and further relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC 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
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
eement are valid and enforceable; and d. Awarding such other and fiirther relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Rosh D. Alger, Esq. VI Bar No. 932 Tel
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,
s Agreement are valid and enforceable; and Awarding such other and further relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC • 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 P
Entities connected to both Fancelli and Rosh D. Alger Esquire

Jeffrey Epstein
PERSONDarren Indyke
PERSONJuan Pablo Molyneux
PERSONthe State of New York
LOCATION
U.S. Virgin Islands
LOCATIONJay Goldberg
PERSON
Saint James
LOCATIONDenise M. Francois
PERSONthe Office Pavilion
ORGANIZATIONBevilacqua Fabric
ORGANIZATIONthe Exhibit B Services
ORGANIZATIONJ.P. Molyneux Studio
PERSONRoyal Dane
ORGANIZATIONAdjudging
LOCATIONStudio
PERSONthe Territory of the
LOCATIONVI Bar No
ORGANIZATIONPunch List
ORGANIZATIONthe Escorial Library
ORGANIZATIONJuan Pablo
PERSON