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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
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; EFTA00310026 Case: 3:10-cv-0003
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
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; 4 EFTA00308305 Case: 3:10-cv-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,
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; 4 EFTA00299559 Case: 3:10-cv-0
Entities connected to both Fancelli and Adjudging

Jeffrey Epstein
PERSONDarren Indyke
PERSONJuan Pablo Molyneux
PERSON
U.S. Virgin Islands
LOCATIONthe State of New York
LOCATIONJay Goldberg
PERSON
Saint James
LOCATIONthe Office Pavilion
ORGANIZATIONDenise M. Francois
PERSONBevilacqua Fabric
ORGANIZATIONthe Exhibit B Services
ORGANIZATIONRoyal Dane
ORGANIZATIONStudio
PERSONRosh D. Alger Esquire
PERSONthe Territory of the
LOCATIONVI Bar No
ORGANIZATIONJuan Pablo
PERSONPunch List
ORGANIZATIONthe Escorial Library
ORGANIZATIONRoth D. Alger
PERSON