Epstein Secrets

in the District Court of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned J.P.Molyneux Studio. Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J., LLC. (the "Molyneux Action'), dated June 11, 2010, arising out of the same 5 EFTA00300057 transaction or series of transactions as th

Punch List items falling under the Design Services Agreement (Molyneux Action, First Amended Complaint, ¶17) * * * On March 25, 2010 Defendants' [Epstein's] agent signed off on all items enumerated on the Punch List by signing it and noting that all the woodwork on the list was done with the exceptio

T. THOMAS & ST. JOHN --------------------1 I ) JEFFREY EPSTEIN, et al., ) ) Plaintiffs, ) ) v. )

d a signature of a person with authority to bind Mr. Epstein. If there are additional items which your client

eux, by Rosh D. Ager, Esq., states under oath that: s. Subsequent to the execution of the Design Services Agreement [between Juan Pablo Molyneux, Molyneux Studio, Ltd. and Jeffrey Epstein and L.S.J., LLC, dated May 15, 2009], Plaintiffs [Molyneux], with the assistance of an internationally-known woodworking crafts

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

Case: 3:10-cv-00034-CVG-RM Document #: 8 Filed: 06/11/10 Page 1 of 5 r DISTRICT COURT OP THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Cash No. 3:1 0-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by'and thro

, @ IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF St THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED MOTION FOR ENLAR

OLL III.. ORDERED THAT DEFENDANT FANCELLI PANELING, INC.'S JANUARY 13, 2011 MOTION TO DISMISS IS DENIED; AND IT IS FURTHER ORDERED THAT PLAINTIFFS JEFFREY ESPSTEIN AND L.S.J., LLC, MUST JOIN AS A PARTY TO THIS ACTION MOLYNEUX STUDIO AND. TO THAT END, MUST FILE A SECOND AMENDED COMPLAINT WITHIN FOURTEEN 14 DAYS

and incorporated herein. EFTA00309172 Motion for Enlargement of Time to File Motion for Reconsideration of Order to Joint Molyneux Studio, Ltd. Epstein vs. Fanceili Paneling, Inc. Civil No. ST-10-O4443 4. The undersigned counsel's office has either an office employee or an independent courier che

es S. Carroll III CASE TYPE: DAMAGES - CIVIL SECONDARY null PETITION PARTY NAME LITIGANT PARTY TYPE L.S.J., LLC , P002 PLAINTIFF EPSTEIN , JEFFREY P001 PLAINTIFF FRANCOIS ESQ., DENISE M P001 ATTORNEY FOR ANY OTHER PARTY FANCELLI PANELING, INC., D001 DEFENDANT MOORE , TRESTON E. D001

of time within which to file Plaintiffs' motion for reconsideration of this Court's Order, entered May 24, 2011, which directs Plaintiffs to joins. Molyneux Studio, Ltd. as a party to this action. As grounds for this Motion for Enlargement of Time, the Plaintiffs rely upon the following: 1. On May 26, 2011, the und

tive Date"), by and among Juan Pablo Molyneux ("JP"),.. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, in exchange for good and valuable consideration, including the mutual agreements, promi

d among Juan Pablo Molyneux ("JP"),.. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, in exchange for good and valuable consideration, including the mutual agreements, promises and ot

, supplies, etc. as per JPMS drawings dated November 15, 2010. Drawings enclosed (5K- 1, SK-2, SK-3 and SK-4) to be signed and dated for approval by J. Epstein. As-built dimensions of 'Sarah's Office' to be verified by Gary Kerney and provided to JP Molyneux Studio. • One desk-top lamp with two arms (Eter

er with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"

IGN SERVICES ("Agreement") is entered into as of this 'JUt day of December, 2010 (the "Effective Date"), by and among Juan Pablo Molyneux ("JP"),.. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, i

Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studi

Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studio would de

State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective com

s the Office Pavilion. 4. In consultation with Mr. Epstein, I created the conceptual design, including cabi

d says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epste

ement for Design Services dated May 15, 2009 ("Design Services Agreement") by and among Juan Pablo Molyneux, Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay and Elizabeth: Further to my February 25, 2010 letter to Jay, I am writing to inform you about an unresolved problem relating to the blac

ised you that the blackboards are not usable, made of the wrong material and must be replaced. Almost a month has passed, and I understand that Mr. Epstein has still received no response from Mr. Molyneux. Please ask Mr. Molyneux to provide a proposal to Mr. Epstein with respect to the replacement of t

Molyneux, Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay and Elizabeth: Further to my F

Almost a month has passed, and I understand that Mr. Epstein has still received no response from Mr. Molyneux

, ew or 10177 March 1, 2010 Re: Agreement for Design Services dated May 15, 2009 ("Design Services Agreement") by and among Juan Pablo Molyneux, Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay and Elizabeth: Further to my February 25, 2010 letter to Jay, I am writing to inform you about an unreso

DS DIVISION OF ST. THOMAS AND ST. JOHN J. P. MOLYNEUX STUDIO, LTD. and ) JUAN PABLO MOLYNEUX, ) ) Plaintiffs, ) Civil No. 2010/34 v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) DEFENDANTS' LRCi 16.1 DISCOVERY MEMORANDUM The Defendants Jeffrey Epstein and L.S.J., LLC (the "Defendants")

ted September 16, 2010: 1. Brief statement of facts underlying the claims or defenses in the action and of the legal issues in the case: In 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-str

for Design Services required Molyneux to credit defendant Epstein for $250,000 "to be applied against future servi

) Plaintiffs, ) Civil No. 2010/34 v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) D

1, 2010 all of the items listed on Exhibit B..." attached to the Agreement for Design Services. 2 EFTA00725568 Defendants' Discovery Memorandum Molyneux Studio, Ltd. vs. Epstein et al. Civil No. 2010/34 Between May 2009 and March 2010, the Library Cabinetry was shipped to Little St. James Island. As of today's

. . . . . . . . . . . . . . . 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., ) ) (CARROLL, J.) Defendant. ) OPPOSITION TO MOTION

ourt held that: EFTA00308324 ii Ii iI In the Factual and Procedural Background section of the Memorandum Opinion, the Court noted that in 2005 Epstein contracted with non-parties — "J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")" — to design a residential project on

rt of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned 4 EFTA00308327 J.P.Molyneux Studio, Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J. LLC. (the "Molyneux Action'), in which Molyncux alleges: [s]ubsequent to the execution of the Design Services Agreement, Plaintiffs, wi

IRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., ) ) ) Plaintiffs, ) ) v.

ersity jurisdiction, 28 U.S.C. § 1331, this Court will not lose subject-matter jurisdiction by requiring the joinder of Mr. Juan Pablo Molyneux and Molyneux Studio, Ltd. Plaintiffs concede that the individual and the entity are subject to service of process. After a review of the matter posed by the existing parties

ective Date"), by and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties"). WHEREAS, disputes have arisen between Molyneux and Studio, on the one hand, and LS

and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties"). WHEREAS, disputes have arisen between Molyneux and Studio, on the one hand, and LS) and Epst

her with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux a

ENT AND RELEASE ("Agreement") is entered into as of this 2 day of December, 2010 (the "Effective Date"), by and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties")