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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
corporations. The affidavit of service of Plaintiff's process server states that he delivered a copy of the Summons and First Amended complaint to "Christian Barthod, co-worker, a person of suitable age and discretion." As noted in the Affidavit of Mr. Christian Barthod, Def. Exhibit B1, he holds no special corp
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
at its offices, 24 East 64th Street, New York, NY on November 29, 2010, by "delivering a true copy of [the Summons and First Amended Complaint] on Christian Barthod, CO-WORKER a person of suitable age and discretion." (emphasis supplied). FAC, Exhibit 1. Plaintiff, in its argument, goes to great lengths to conv
Ift.MILA rk" CAS 11.41 V t3-3 I0.)3!3 ' EFTA00299532 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.) ) STATE OF NEW YORK
SION OF ST. THOMAS & ST. JOHN * * * * * JEFFREY EPSTEIN, et al., ) ) ) Plaintiffs, ) ) v. ) NO.
itC040Ct. roe ryaq iiIVEPSM/OFFICE EPSIII It JEFFREY &MEIN 9 EAST 71ST SWEET ICI RAC NY 10022 OFFI
siness card. When I went to get it, he took his bag from the chair and placed it on the work table. I handed him my card and he confirmed that I am Christian Barthod. 5. I requested his card, but instead he pulled out a large yellow envelope. He said, "I hope you are not going to be mad, but I have to do this, I
Entities connected to both Jeffrey Epstein and Christian Barthod

Prince Charles
PERSON
New York
LOCATION
Russell Simmons
PERSONFancelli
PERSONDenise Francois
PERSONEscorial
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATIONNeitzke v. Williams
PERSONMolyneux Studio, Ltd.
ORGANIZATIONFancelli Paneling
PERSONthe Exhibit B Services
ORGANIZATIONPringle
PERSONBlue Cross & Blue Shield
ORGANIZATIONthe Court of the facts of the
ORGANIZATIONFrederick Pringle
PERSONLeuthner
PERSON