Epstein Secrets

November 2009 Jay Goldberg, Esq. 250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about two important and time-sensitive issues which h

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about two important and time-sensitive issues which have arisen in connection wit

ovember 4, 2009 Jay Goldberg, Esq. 250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to you in order to prevent what could soon become a breach by your

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to you in order to prevent what could soon become a breach by your clients of their obligations

cember 14, 2009 Jay Goldberg, Esq. 250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I wanted to make sure that you were up to date on the outstanding issues re

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I wanted to make sure that you were up to date on the outstanding issues relating to the performance of

cument #: 18 Filed: 08/25/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRICT COURT OF THE VIRGIN ISLANDS ) ) ss: DIVISION OF ST. THOMAS

ld be denied. Dated: August 25, 2010 St. Thomas, U.S. Virgin Islands 5/ Rosh D. Alger Rosh D. Alger, Esq. Attorney for Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux VI Bar No.932 PMB 10 Royal Dane Mall #12 St. Thomas. VI 00802 Tel. Fax 5 EFTA00731231

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

ion for reconsideration of this Court's Order entered on May 24, 2011 requiring Plaintiffs to file a Second Amended Complaint adding J. P. Molyneux Studio, Ltd. as a party on the grounds that such a forced joinder will create manifest injustice. For the reasons set forth below, the Plaintiffs' motion for rec

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

12 EFTA00307589 Memorandum in Support of Plaintiffs' Motion for Reconsideration Epstein et al vs. Fancelli Paneling, Inc. Case No. ST-IO-CV-443 Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J, LLC filed in the District Court of the Virgin Islands, Division of St. Thomas and St. John as