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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
s") submit this memorandum in support of their motion for reconsideration of this Court's Order entered on May 24, 2011 requiring Plaintiffs to add J. P. Molyneux Studio, Ltd. as a party on the grounds of clear error, and because such a forced joinder will create manifest injustice. For the reasons set forth below, Plaint
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hich was in excess $780,000, plus additional expenses incurred to correct the defects in the Library Cabinetry, the loss of use of the funds paid to Fancelli through Molyneux; and the loss of time and effort of the Plaintiffs' staff, and the expenditure of funds, in the attempt to obtain Fancelli's perfo
VI 00802, Telephone: 340-774-6845 D. Juan Pablo Molyneux, 750 Lexington Ave., 5111 FL, New York, NY 10022, Telephone: 212-628-0097 E. Doug Stine, J. P. Molyneux Studio, Ltd. 750 Lexington Ave., 51h Fl., New York, NY 10022, Telephone: 212-628-0097 As of the date of this Disclosure Statement, the Defendant has not filed a
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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
at this Court grant their motion for reconsideration and revise the Order entered on May 24, 2011, to the 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
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Mutual Connections (27)
Entities connected to both Fancelli and J. P. Molyneux Studio, Ltd.
Jeffrey Epstein
PERSON197 w/ Fancelli·4 w/ J.
DF
Denise Francois
PERSON16 w/ Fancelli·4 w/ J.
JM
Juan Pablo Molyneux
PERSON15 w/ Fancelli·3 w/ J.
TM
Treston E. Moore
PERSON8 w/ Fancelli·4 w/ J.
MOORE DODSON & RUSSELL
ORGANIZATION10 w/ Fancelli·2 w/ J.
Studio, Ltd.
ORGANIZATION8 w/ Fancelli·2 w/ J.
Prince Charles
PERSON7 w/ Fancelli·2 w/ J.
FRANCOIS
LOCATION4 w/ Fancelli·3 w/ J.
the Library Cabinetry
ORGANIZATION3 w/ Fancelli·3 w/ J.
BO
Bostic
PERSON4 w/ Fancelli·2 w/ J.
Scarlett Johansson
PERSON3 w/ Fancelli·2 w/ J.
Balfour Beatty
ORGANIZATION3 w/ Fancelli·2 w/ J.
Quinteros
ORGANIZATION2 w/ Fancelli·2 w/ J.
JM
J. P. Molyneux
PERSON2 w/ Fancelli·2 w/ J.
LO
Lou-Ann
PERSON2 w/ Fancelli·2 w/ J.
Local Rule of Civil Procedure 7.3
ORGANIZATION2 w/ Fancelli·2 w/ J.
Syosset, Inc.
ORGANIZATION2 w/ Fancelli·2 w/ J.
Post Properties, Inc.
ORGANIZATION2 w/ Fancelli·2 w/ J.
Baltica-Skandinavia Ins. Co. Ltd.
ORGANIZATION2 w/ Fancelli·2 w/ J.
Porter, Sea I & Co.
ORGANIZATION2 w/ Fancelli·2 w/ J.