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

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)

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.

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

ICATE OF SERVICE I hereby certify that on this 5th day of July, 2011, a copy of the foregoing was served by first class mail, postage prepaid, upon Denise Francois, Esquire, Hodge & Francois, #1340 Taameberg, St. Thomas, V.I. 00802. 15 EFTA00308338

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