Epstein Secrets

to Mr. Jean Pierre Fancelli. 5 In addition, Defendant specifically informed Plaintiffs' counsel, Darren lndyke, that because of limitations with Mr. Fancelli's ability to communicate in English, Mr. lndyke should communicate with Mr. Fancelli through Mr. Barthod . Pl. Ex. 3 Thus, Mr. Barthod has been pre

Ex. 4. In support of its argument for insufficient service of process, Defendant asserts that the ...Summons and Complaint (sic) were delivered to Fancelli's office in New York on or about November 29, 2010 and left at that location with an unauthorized employee of Fancelli Paneling, Inc." However, Mr.

e, the Defendant's Motion to Dismiss the Complaint with Points and Authorities should be denied in its entirety. Respectfully submitted, HODGE AND FRANCOIS Dated: Z ( 1 1 1 2-O11 By: setWAYD Denise Francois V.I. Bar Association #285 1340 Taameberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (340)

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

ng Plaintiffs to join J. P. Molyneux Studio, Ltd. as a party to the above- captioned action. Dated: 6, 12 ( Rol f Respectfully submitted, ODGE AND FRANCOIS . Denise Francois 1340 Taameberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (340) 776-7720 Email: [email protected] Attorneys for Je

ork, which is engaged in the business of restoration and reproduction of antique wood panels and cabinetry in the United States, Canada and Europe. Fancelli's website at http://www.fancelli-paneling.com advertises Jean- Pierre Fancelli as a master of his craft, trained as an architect who "works directly

such further relief as this Court deems appropriate. PLAINTFFS DEMAND A TRIAL BY JURY ON ISSUES TRIABLE BY JURY Respectfully submitted, HODGE AND FRANCOIS Dated: July , 2010 By: Denise Francois V.I. Bar Association #285 1340 Taameberg St. Tel. 1~ Fax. Email: Attorneys for Jeffrey Epstein and L

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

extent that it requires Plaintiffs to add J. P. Molyneux Studio, Ltd. as a party to the above-captioned action. Respectfully submitted, HODGE AND FRANCOIS Dated: 647 (2.C.) ( CuLuiyo Denise Francois 1340 Taameberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (340 776-7720 Email: Attorneys for Je