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erre Fancelli, and the actions of Fancelli Paneling, Inc. and Atelier Fancelli are indistinguishable. 4,5 In 2005, Epstein engaged the 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
such further relief as this Court deems appropriate. PLAINTFFS DEMAND A TRIAL BY JURY ON ISSUES TRIABLE BY JURY Respectfully submitted, HODGE AND FRANCOIS Dated: July , 2010 By: Denise Francois V.I. Bar Association #285 1340 Taameberg St. Tel. 1~ Fax. Email: Attorneys for Jeffrey Epstein and L
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
d. as a party to the above-captioned action. A proposed form of order is attached for the Court's consideration. Respectfully submitted, HODGE AND FRANCOIS Dated: 6 (3I I 2-O11 By: ?I &(.t. O Denise Francois V.I. Bar Association #285 1340 Taarneberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (
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
extent that it requires Plaintiffs to 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 Je
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
ng Plaintiffs 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 Je
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
endant require the denial of Defendant's Motion to Dismiss which has evolved into a Motion for Summary Judgment. Respectfully submitted, HODGE AND FRANCOIS Dated: 3129 (2-01 1 By: Denise Francois aLcusiki Tel. Fax. ( Emai Attorneys for Jeffrey Epstein and L.SJ., LLC 8 EFTA00308346 Plaintiffs'
Entities connected to both Juan Pablo Molyneux and FRANCOIS

Jeffrey Epstein
PERSONDarren Indyke
PERSONFancelli
PERSONL.S.J.
ORGANIZATIONthe State of New York
LOCATION
Prince Charles
PERSONTreston E. Moore
PERSON
U.S. Virgin Islands
LOCATIONDenise Francois
PERSONU. S. Mail
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATIONStudio, Ltd.
ORGANIZATION
Saint James
LOCATIONthe Superior Court
ORGANIZATIONMaria Farmer
PERSON
St. John
LOCATIONJ. P. Molyneux Studio, Ltd.
ORGANIZATION
St Thomas
LOCATIONBalfour Beatty
ORGANIZATION
Scarlett Johansson
PERSON