Epstein Secrets

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

e 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. All documents and things produce

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

THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein etab vs. Fanelli Paneling, Inc. Super. Cs Case No. ST-10-CV-443 of contract and negligence because the Library Cabinetry is defective and installation was incomplete. Plaintiffs and Molyneux entered into a confidential settlement agreement and release (the "Confidenti

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.

). 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 improper and incomplete. Fancelli was served with the Summons and First Amended Complaint on December 3, 201