Epstein Secrets

ATE OF SERVICE I hereby certify that on this lath day of March, 2011, a copy of the foregoing was served by first class mail, postage prepaid, upon Denise Francois, Esquire, Hodge & Francois, #1340 Taarneberg, St. Thomas, V.I. 00802. EFTA00310017 § 308. CPLR effective unless the front .of the envelope bear

EFENDANT IS SUBJECT TO INQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on

Upon discovering various deficiencies in Fancelli's work, Plaintiffs, as third party I Plaintiffs Jeffrey Epstein and L.S.J., LLC are represented by Denise Francois, Esq. Defendant Fancelli P eling, Inc., is represented by Treston E. Moore, Esq. 2 For a complete recitation of the factual and procedural history

16, 2011 Order followi g its Memorandum Opinion, the Court intended to order the Plaintiffs to add J.P. Molyneux S dio, Ltd. to the action and not Juan Pablo Molyneux individually. FACTUAL AND PROCEDURAL BACKGROUND The Court will give a brief recitation of the facts and procedural history that are re evant to th

s pursuant to Fed. R. Civ. P. 37 as the circumstances may warrant. Respectfully submitted, HODGE & FRANCOIS Dated: id 171201 1 By: CUACti2/1.) Denise Francois, Esquire 1340 Taarneberg St. Thomas, VI 00802 Tel: 340-774-6845 Fax: 340-776-7720 deniseehodgefrancois.com 5 EFTA00309168 Plaintiff's' Rule

hotographs relating to the Office Pavilion and Library Cabinetry which are the subject of the Plaintiffs' First Amended Complaint. C. Affidavit of Juan Pablo Molyneux relating to the Library Cabinetry. D. Video of incomplete and defective Library Cabinetry in the Office Pavilion on Little Saint James Island. E.

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 Jeffrey Epstein and LLC 10 EFTA00307571 MEMO

sideration should be granted. I. BRIEF STATEMENT OF RELEVANT FACTS AND PROCEDURAL HISTORY OF CASE In 2005, Plaintiffs contracted with non-parties Juan Pablo Molyneux, a resident of the State of New York, and his company, I. Molyneux Studio, Ltd. (collectively "Molyneux"), a New York corporation, to design a resi

s 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 Jeffrey Epstein and L.

tion for reconsideration should be granted. I. STATEMENT OF RELEVANT FACTS AND PROCEDURAL HISTORY. In 2005, Plaintiffs contracted with non-parties Juan Pablo Molyneux ("JP"), a resident of the State of New York, and his company, J.P. Molyneux Studio, Ltd. ("Molyneux"), a New York corporation, to design a resident