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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
to which Defendant fabricated and installed the subject cabinetry is a Purchase Order #2680 dated June 15, 2006, between "MOLYNEUX" and Defendant, Fancelli Paneling, as replaced by Purchase Order #7106 dated October 14, 2008, the full scope of which is as follows: Woodworking FABRICATION & INSTALLATION of light
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
d it cannot be as designated for residents EFTA00310005 DEE rpste Page DANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS , et al. v. Fancelli Paneling. Inc. of the Virgin Islands with an enduring relationship. See 5 § 4902. Plaintiffs readily admit the fact that Defendant is not subject to this C
" items designated by Fancelli as "New Work," both relating to the St. James Project, we request that: A] Juan Pablo Molyneux, Molyneux Studio and Jeffrey Epstein, each by authorized representative, shall acknowledge that the scope of work designated by Mr. Indyke as "Complaint Punch List" items "1" thro
T. JAMES PROJECT Gentlemen: Attached hereto are Fancelli Paneling work proposals, inclusive of: (i) Fancelli's response to items described in Mr. Epstein's September 8th E-Mail and designated "1" through "10" in the "Indyke Complaint Punch List"; (ii) proposal for "New Work" orders, submitted for a
n, by authorized representative, shall agree not to effect service of process in the above identified action or in any other action in which either Jeffrey EFTA00726703 Epstein, L.S.J., LLC or any other entity in which Epstein has a direct or beneficial interest, is a party, upon Fancelli Paneling,
f: (i) Fancelli's response to items described in Mr. Epstein's September 8th E-Mail and designated "1" throu
ation to Molyneux Studio and to have satisfied each alleged grounds identified in the Complaint in an action designated, Epstein and L.S.J., LLC v. Fancelli Paneling, Inc., bearing a Case No. ST-10-CIV. 443; and AGREED AND APPROVED Jeffrey Epstein By AGREED AND APPROVED Juan Pablo Molyneux Molyneux Studio
" items designated by Fancelli as "New Work," both relating to the St. James Project, we request that: A] Juan Pablo Molyneux, Molyneux Studio and Jeffrey Epstein, each by authorized representative, shall acknowledge that the scope of work designated by Mr. Indyke as "Complaint Punch List" items "1" thro
T. JAMES PROJECT Gentlemen: Attached hereto are Fancelli Paneling work proposals, inclusive of: (i) Fancelli's response to items described in Mr. Epstein's September 8th E-Mail and designated "1" through "10" in the "Indyke Complaint Punch List"; (ii) proposal for "New Work" orders, submitted for a
n, by authorized representative, shall agree not to effect service of process in the above identified action or in any other action in which either Jeffrey EFTA00585985 Epstein, L.S.J., LLC or any other entity in which Epstein has a direct or beneficial interest, is a party, upon Fancelli Paneling, In
f: (i) Fancelli's response to items described in Mr. Epstein's September 8th E-Mail and designated "1" throu
ation to Molyneux Studio and to have satisfied each alleged grounds identified in the Complaint in an action designated, Epstein and L.S.J., LLC v. Fancelli Paneling, Inc., bearing a Case No. ST-10-CIV. 443; and AGREED AND APPROVED Jeffrey Epstein By AGREED AND APPROVED Juan Pablo Molyneux Molyneux Studio
Francois Guyot, Esq. Fancelli Paneling, Inc. A. Jeffrey Weiss. Esq. reston E. Moore EFTA00621950
the numbers in that language. At that juncture, Mr. Epstein took over the conversation, surprised that Mr. Fa
mile September 11, 2012 VIA FACSIMILE TRANSMISSION & MAIL Denise Francois, Esquire Hodge & Francois 1340 Taarneberg St. Thomas, V.1.00802 RE: EPSTEIN. et at v. FANCELLI PANELING. INC.. Dear Attorney Francois: My Associate, Michele Baker, just concluded a conversation with Mr. Fanelli and his Fre
does not want pictures, he wants the work inspected and evaluated by our expert. EFTA00621949 LETTER TO DENISE FRANCOIS, ESQ, Epstein, et al. v. Fancelli Paneling. Inc.. el al. Page 2 Mr. Fancelli agreed to meet with him when Mr. Epstein came to France in October. but with his lawyer. Mr. Fancelli did not ag
St Chien France infoafancelli-panelina.com From: Brice Gordon [mailto: Sent: Tuesday, May 12, 2009 9:01 AM To: JP Molyneux; Fancelli Paneling; 3 Epstein Subject: FW: Report 118 To: P Confirming that the Office Pavilion will be ready for Fenceli Installers to start on the 18th May, 2009 JP can you
York, NY 10021 93400 St Chien France infoafancelli-panelina.com From: Brice Gordon [mailto: Sent: Tuesday, May 12, 2009 9:01 AM To: JP Molyneux; Fancelli Paneling; 3 Epstein Subject: FW: Report 118 To: P Confirming that the Office Pavilion will be ready for Fenceli Installers to start on the 18th May, 2009
Entities connected to both Jeffrey Epstein and Fancelli Paneling
Darren Indyke
PERSON
Prince Charles
PERSON
New York
LOCATION
Russell Simmons
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSONDenise Francois
PERSONJay Goldberg
PERSONMOORE DODSON & RUSSELL
ORGANIZATIONthe Office Pavilion
ORGANIZATIONNeitzke v. Williams
PERSONMolyneux Studio, Ltd.
ORGANIZATIONSt. James Island
LOCATIONthe Exhibit B Services
ORGANIZATIONEuros
LOCATIONBlue Cross & Blue Shield
ORGANIZATIONChristian Barthod
PERSONFancelli Attachment
ORGANIZATIONJAMES PROJECT
PERSONLeuthner
PERSON