Epstein Secrets

ble Debra C. Freeman May 18, 2020 Page 2 Further, Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation. When

gh her criminal conduct would be directly at issue in that case, and the case would require discovery concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); Willie v. Amerada Hess Corp., 66 V.I. 23, 92 (Super. Ct. 2017) (common law indemnification is only available

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.);

ry concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); W

at issue in that case, and the case would require discovery concerning such conduct. Maxwell v. Estate of Jeffrey E. Epstein, et at, ST-20-CV-155 (V.I. Super. Ct.); Willie v. Amerada Hess Corp., 66 V.I. 23, 92 (Super. Ct. 2017) (common law indemnification is only available "where an innocent party is hel

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,

egations and construes factual disputes in favor of the non-moving party. Bertrand v. Cordther Enters., Inc., ST-OS-CV-457, 2010 WL 2507305, at 418 (V.I. Super. Ct June 2, 2010) (citing Paradise Motors, Inc. v. Toyota de Puerto Rico Corp., 314 F. Supp. 2d 495, 499 (DN.I. 2004)). 3 L.S.J. is a Delaware cor

e an encumbrance on the servient estate. Louis W. Epstein Family Pship v. Kmart Corp., 13 F.3d 762, 773 (3

laint must put the defendant on fair notice of the claims being brought against him or her. Finn v. Adams, No. ST-16-CV-752, 2018 WL 3756421, at *4 (V.I. Super. Aug. 6, 2018). A statute of limitations defense is an affirmative defense that must be raised in a defendant's first responsive pleading, which i