Epstein Secrets

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.

VI 00802, Telephone: 340-774-6845 D. Juan Pablo Molyneux, 750 Lexington Ave., 5111 FL, New York, NY 10022, Telephone: 212-628-0097 E. Doug Stine, J. P. Molyneux Studio, Ltd. 750 Lexington Ave., 51h Fl., New York, NY 10022, Telephone: 212-628-0097 As of the date of this Disclosure Statement, the Defendant has not filed a

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

at this Court grant their motion for reconsideration and revise the Order entered on May 24, 2011, to the 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

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

s") submit this memorandum in support of their motion for reconsideration of this Court's Order entered on May 24, 2011 requiring Plaintiffs to add J. P. Molyneux Studio, Ltd. as a party on the grounds of clear error, and because such a forced joinder will create manifest injustice. For the reasons set forth below, Plaint