Epstein Secrets

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

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

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

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") 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

). 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