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eux, by Rosh D. Ager, Esq., states under oath that: s. Subsequent to the execution of the Design Services Agreement [between Juan Pablo Molyneux, Molyneux Studio, Ltd. and Jeffrey Epstein and L.S.J., LLC, dated May 15, 2009], Plaintiffs [Molyneux], with the assistance of an internationally-known woodworking crafts
laintiffs [Molyneux], with the assistance of an internationally-known woodworking craftsman [Fancelli Paneling, Inc.], undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement (Molyneux Action, First Amended Complaint, ¶14). On March 22, 2
Case: 3:10-cv-00034-CVG-RM Document #: 8 Filed: 06/11/10 Page 1 of 5 r DISTRICT COURT OP THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Cash No. 3:1 0-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by'and thro
hat agreement and the reasonable expectations .of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
ersity jurisdiction, 28 U.S.C. § 1331, this Court will not lose subject-matter jurisdiction by requiring the joinder of Mr. Juan Pablo Molyneux and Molyneux Studio, Ltd. Plaintiffs concede that the individual and the entity are subject to service of process. After a review of the matter posed by the existing parties
greement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman [Fancelli Paneling, Inc.], undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement (Molyneux Action, First Amended Complaint,¶14) On March 22, 2010..
Entities connected to both Molyneux Studio, Ltd. and the Exhibit B Services

Jeffrey Epstein
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSONthe State of New York
LOCATIONJay Goldberg
PERSONMOORE DODSON & RUSSELL
ORGANIZATIONDarren Indyke
PERSONDenise Francois
PERSONRoyal Dane
ORGANIZATIONthe Office Pavilion
ORGANIZATIONJuan Pablo
PERSONEscorial
LOCATION
New York
LOCATIONChristian Barthod
PERSONNeitzke v. Williams
PERSONLeuthner
PERSONFancelli Paneling
PERSON
Russell Simmons
PERSONFirst Amended Complaint
ORGANIZATIONBlue Cross & Blue Shield
ORGANIZATION