Epstein Secrets

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) Plaintiffs, vs- ) ) ) CASE NO. ST-10-CV-443 ACTION FOR DAMAGES C • ) C; C I FANCELLI PANELING, INC., ) ) JURY T

. The FAC was properly served at the Defendant's correct business address on EFTA00309181 Plalnr f s' Opposition to Defendant's Motion to Dismiss Epstein et al. VS. Fanelli Paneling. Inc. Case No. ST-10-CK443 Defendant's President in care of Christian Barthod, who has previously acted as the Presiden

epaid on this 11'" day of February, 2011. bb K1/4 BRAD. 4 C( 30 EFTA00309210 Superior Court of the Virgin Islands - Division of St. Thomas - St. John JEFFREY EPSTEIN AND L.S.J., LLC Plaintiff v. FANCELLI PANELING, INC. Defendant STATE OF New York. COUNTY OF Nassau ss: ) Index No.: ST-10•CIV-443 ) Filing Da

RGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) Plaintiffs, vs-

wholly owned by a Virgins Island resident (i.e., Mr. Epstein), maintains its principal address in the Virgin I

inst Defendant for failure to correct the multitude of 27 EFTA00309207 Plaintiffs' Opposition to Defendant's Motion to Dismiss Epstein et al. it Falwell' Paneling. Inc. Case No. ST-I0-CV-443 defects in and to properly and fully complete the fabrication, installation, staining and finishing of the L

RGIN ISLANDS' DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., * * * * * ) ) ) Plaintiffs,

MAR 1 4 2011I IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS' DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., * * * * * ) ) ) Plaintiffs, ) ) v. ) NO. ST-10-CV-443 ) FANCELLI PANELING, INC., ) ) Defendant. ) (CARROLL, J.) ) I DEFEND

t the outset that Plaintiffs' failed to reference the V.I. long-arm EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Def

00310020 03/10/11 11:1SAM HP LASF.RJET FAX p.02 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN * * * * * ) JEFFREY EPSTEIN, et al, ) ) Plaintiffs, ) v. ) NO. ST-I 0-CV-443 ) FANCELLI PANELING, INC., ) ) Defendant. ) (CARROLL,I) ) STATE OF NEW YORK ) COUN

led himself of the benefits and protections of the EFTA00310011 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS &stein. et at v. Falwell' Paneling. Inc. Page laws of the forum state." Burger King Corp., 471 U.S. at 474-476. The purposeful availment requirement "ensures that a defend

lialonancto aoiaaans 9698922 : fiq VIOS EFTA00307083 FOR PUBLICATION IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING, INC., Plaintiffs, Defendant. DENISE FRANCOIS, ESQ. Hodge & Francois 1340 Taameberg St. Thomas, U.S. V

2 is the sole member of Plaintiff L.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little

Renaissance exchanged phone calls, faxes and emalls with s in :Bd e8S:00 TT -1.2-90 HU373/120103 aolHudns 0690912 : fiq Was xed EFTA00307088 Jetey Epstein v. Fancelli Paneling Inc. Civil No. ST-10-CV-443 Memorandum Opinion Page 6 of II foreign corporation engages in reciprocal communications with a

GIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING,

ent or through service upon the Secretary of State. In addition, Fancelli argues that it is not a citizen or resident of the Virgin Islands, does 2 Falwell' alleges In Its Motion to Dismiss that Epstein is also a resident of New York, NY, and Palm Beach, Florida. However, the Court accepts as true the n

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., Defendant. CASE NO. ST-I 0-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED 0N.) PLAIN

was essentially a motion, will also be addressed below. EFTA00308339 Plaint10' Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Fanelli Paneling. Inc. Case No. ST-10-CV-443 I. PROCEDURAL HISTORY. On March 4, 2011 Plaintiffs and Defendant filed a Stipulation to Ex

ummary 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' Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Fancelli Panelin

GIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCE

ly chose not to do so. That they 3 EFTA00308341 Plaintif/i• Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Falwell, Paneling, Inc. Case No. ST-10-CV-443 subsequently choose to do so now in violation of the rules of the Court should not be countenanced. II. DE

: 191694 The Suppression of Science: The Case of Jeffrey MacDonald A case in which science has not yet pr

hich a celebrity described “his first time.” The ad relies on the obvious double-entendre on the first sexual and drinking experience. In the parody, Falwell is shown drinking and having sex with his mother—pretty disgusting! But as the Supreme Court rightly observed: 150 HOUSE_OVERSIGHT_017237 4.2.12 W