Epstein Secrets

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

ird 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 in this matter see this Court's May 1 2011 Memorandum Opinion. Epstein v.

rder entered on May 24, 20112, there exists a confidential settlement agreement and release (the "Confidential Agreement") by and among Plaintiffs, Juan Pablo Molyneux and J. P. Molyneux Studio, Ltd. which prohibits Plaintiffs from revealing any facts about the Confidential Agreement or its terms without first giv

ERTIFICATE OF SERVICE I HEREBY CERTIFY THAT that I caused a true and correct copy of the foregoing Motion for Enlargement of Time to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL P.O. Box 310, St. Thomas, VI 00804 b first class U. S. Mail, postage prepaid on this St 4 day of June, 2011 and b

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.

, I hereby certify that I caused the foregoing Plaintiffs' Rule 26(a) Initial Disclosure Statement to be served via U.S. Mail, postage prepaid upon Treston E. Moore, Esquire, Moore, Dodson & Russell, P.C. at P.O. Box 310, St. Thomas, VI 00804-0310. 11-nate.htlik Anna Iti cttl3 6 EFTA00309169

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

ue and correct copy of the foregoing MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR ECONSIDERATION OF ORDER ENTERED 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 r day of -1t.t , 201

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

y of the foregoing MEMORANDUM 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 ,

y shows that the primary, if not sole purpose of the Amended Reply is to attempt to refute, with the use of 7 additional exhibits, the Affidavit of Juan Pablo Molyneux that Plaintiffs filed in support of their Opposition to Defendant's Motion to Dismiss. As all of the arguments and materials used in the Amended Re

ed a true and correct copy of the foregoing Plaintiffs' Opposition to Defendant's Motion for Leave to File An Amended Reply Brief 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 ,Qcrt- day of ?-La r rU.