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SION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.SJ., LLC. X PLAINTIFFS, by and through the undersigned counsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMO
Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was constructing on Little Saint James. 10.Subsequently, disputes arose between the parties with respect to the design services to be provided by
s of the date of the day and year first above-written. MOLYNEUX STUDIO, LTD. 0 lo Pefolynen; • MOLYNEUX • JEFFREY EPSTEIN • L.S.J., LLC By: JAMEY EPSTEIN ?&ember - 5 EFTA00299573 Case: 3 1 0-cv-000 34-C(7G4DVI[siLladjin ent it 8-3 Filed: 06/11/1 OntF hagess41forMumf 7, 06 29 FAST69,a Srstf:ET
DED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.SJ., LLC. X PLAINTIFFS, by and t
d a signature of a person with authority to bind Mr. Epstein. If there are additional items which your client
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
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
laintiffs [Molyneux], with the assistance of an internationally-known woodworking craftsman [Fancelli Paneling, Inc.], undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement (Molyneux Action, First Amended Complaint, ¶14). On March 22, 2
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
hat agreement and the reasonable expectations .of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
. . . . . . . . . . . . . . . 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.
greement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman [Fancelli Paneling, Inc.], undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement (Molyneux Action, First Amended Complaint,¶14) On March 22, 2010..
ICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRICT COURT OF THE VIRGIN ISLANDS ) ) ss: DIVISION OF ST. THOMAS AND ST. CROIX ) AFFIDAVIT OF ROSH D. ALGE
S. Virgin Islands. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was constructing on Little Saint James. Subsequently, disputes arose between the parties with respect to the design services to be provided by Plai
Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRI
n of the Design Services Agreement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman, undertook to and did perform the Exhibit B Services, with the exception of the restaining and refinishing of the wood cabinetry. On January 26 and 27, 2010, Plaintiffs travelled to Little Saint Jame
case may be, as of the date of the day and year first above-written. J.P. MOLYNEITX STUDIO, LTD. •By: Juan Pablo Molyneux Pres • LO MOLYNEUX JEFFREY P.PSTEIN L.$.1.,LLC By: JEFFREY EPSTEIN Member EFTA00308319 Case: 3:10-cv-00034-CW-ITNIbifor ernent #: 83 Filed: 06/11/10(1PagerlQuisfenrit MOL,N1
Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was constructing on Little Saint James. 10.Subsequently, disputes arose between the parties with respect to the design services to be provided by
Suit from my BlackBerry0 wireless device From: Jeffrey Epstein <jeevacationggmailcom> Date: 7:14:35-04
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
Entities connected to both Jeffrey Epstein and the Exhibit B Services
Darren Indyke
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Saint James
LOCATIONthe State of New York
LOCATION
Russell Simmons
PERSONFancelli
PERSON
Patty
PERSONJuan Pablo Molyneux
PERSONDenise Francois
PERSONJay Goldberg
PERSONEscorial
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATIONthe Office Pavilion
ORGANIZATIONFirst Amended Complaint
ORGANIZATIONStudio
PERSONDenise M. Francois
PERSONIncluding
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATIONStudio, Ltd.
ORGANIZATION