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h other and further relief as the Court deems just and proper. alb Dated this /1, th day of March, 2011. Respectfully s Treston E V.I. Bar 10 MOORE DODSON & RUSSELL, P.C. Attorneys for Defendant 5035 Noire Gad; P.O. Box 310 St. Thomas, VI 00804-0310 PHONE: FAX: EMAIL: CERTIFICATE OF SERVICE I hereby certif
EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Defendant's Motion to Dismiss on point, to the extend that 5 V.I.C. § 4903(a)(I) & (2)
UM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED ON MAY 24, 2011, to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this Is day of tin rI•P , 2011. ait,Cut 6 la& Anna ltftcCo
fs are contractually prohibited from suing or initiating, prosecuting, participating in or otherwise pursuing a suit against Molyneux. l A copy of First Amended Complaint filed in J.P. Molynex Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J., LLC filed in the District Court of the Virgin Islands, Div
and further relief as the Court deems just and proper. Dated this S . th day ofJuly, 2011. Respectfully submitted, Treston . Moo V.I. B o. 10 MOORE DODSON & RUSSELL, M. PHONE: FAX: EMAIL: CERTIFICATE OF SERVICE I hereby certify that on this 5th day of July, 2011, a copy of the foregoing was served by first
11. Defendant maintains that the Court Granted, in part, its Motion to Dismiss, pursuant to Fed. R. Civ. P. 12(b)0, with dismissal of the existing First Amended Complaint as the appropriate remedy for the relief requested. 12. Defendant acknowledges, however, that the Court may exercise its discretion to join parti
Entities connected to both MOORE DODSON & RUSSELL and First Amended Complaint

Jeffrey Epstein
PERSONDenise Francois
PERSONFancelli
PERSON
U.S. Virgin Islands
LOCATIONthe District Court of the Virgin Islands
ORGANIZATION
Prince Charles
PERSONJuan Pablo Molyneux
PERSON
New York
LOCATION
Scarlett Johansson
PERSONthe Superior Court
ORGANIZATIONStudio, Ltd.
ORGANIZATION
Russell Simmons
PERSONthe State of New York
LOCATIONBostic
PERSONV.I.C.
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATIONthe Exhibit B Services
ORGANIZATIONNeitzke v. Williams
PERSON
Puerto Rico
LOCATIONDarren Indyke
PERSON