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in the Plaintiffs' First Amended Complaint: A. Jeffrey E. Epstein, do Fiodge & Francois, 1340 Taameberg, St. Thomas
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.I., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED PLAINTIFFS'
). The following are individuals likely to have discoverable information regarding the incident raised in the Plaintiffs' First Amended Complaint: A. Jeffrey E. Epstein, do Fiodge & Francois, 1340 Taameberg, St. Thomas, VI 00802, Telephone: 340-774-6845 B. Doug Schoettle, do Hodge & Francois, 1340 Taameberg, St. Th
iffs' First Amended Complaint, and both the Plaintiffs and the Defendant have motions to 2 EFTA00309165 Plaint** Rule 26(a) Required Disclosures Epstein et al v. Fancelli Paneling, Inc. Case No. ST-Ill-CV-443 reconsider pending. When the Defendant does file an Answer to the First Amended Complaint,
in the Plaintiffs' First Amended Complaint: A. Jeffrey E. Epstein, do Fiodge & Francois, 1340 Taameberg, S
in the Plaintiffs' First Amended Complaint: A. Jeffrey E. Epstein, do Fiodge & Francois, 1340 Taameberg, St
omas, VI 00802, Telephone: 340-774-6845 C. Gary Kemey, do Hodge & Francois, 1340 Taameberg, St. Thomas, VI 00802, Telephone: 340-774-6845 D. Juan Pablo Molyneux, 750 Lexington Ave., 5111 FL, New York, NY 10022, Telephone: 212-628-0097 E. Doug Stine, J. P. Molyneux Studio, Ltd. 750 Lexington Ave., 51h Fl., N
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
and through the undersigned counsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. PlaintiffJuan Pablo Molyneux is a citizen of the State of New York. 2. PlaintiffJ.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal
t they will not continue to come off. In the alternative an additional $50,000 payment for the handles would be acceptable and they will become Mr. Epsteins issue; 2. The concealed hardware inside the swinging bookcases at the entry doors is falling off. The screws are too short for proper attachment to
ST) - Resolution Agreement - Oct 2010 Page 9 / 22 EFTA00721954 PANELING PUNCH LIST SEPT 8th 2010 Sent from my BlackBerry wireless device From: Jeffrey Epstein Date: Wed, 8 Sep 2010 09:16:48 -0400 To: ja> Subject: 1. The decorative brass handles on the hardware holding the upper bookcases closed are syst
0 Sent from my BlackBerry wireless device From: Jeffrey Epstein Date: Wed, 8 Sep 2010 09:16:48 -0400 To
handles would be acceptable and they will become Mr. Epstein's issue; NO not acceptable Our client, Molyne
. James Office 750 Lexington Avenue NEW COLOR — New York, NY 10022 Job PHASE ONE: (212) 628-0097 Reference: SAMPLE DEFINITION VIA EMAIL Juan Pablo Molyneux As per Designated Punch List & Proposed New Work NEW WORK: NEW COLOR STAINING PHASE ONE: SAMPLE DEFINITION Item Description Terms of payment Cu
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
THIS SETTLEMENT AGREEMENT 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 M
sign Services Agreement") by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd. (collectively, "Molyneux"), L.S.J., LLC ("LSI") and leffrey Epstein ("Epstein") This is in regard to the above-referenced Design Services Agreement. Among other things, Sections 5 and 8 of the Design Services Agreem
ce provided below and returning the same to Darren K. Indyke, Esq., 301 East 66th Street, 10B, New York, New York 10065, fax:I email: Sincerely, Jeffrey Epstein and L.S.J., LLC AGREED TO BY: Juan Pablo Molyneux, individually, and on behalf of J.P. Molyneux Studio, Ltd. EFTA00727560
York, New York 10065, fax:I email: Sincerely, Jeffrey Epstein and L.S.J., LLC AGREED TO BY: Juan Pab
January 27, 2010 VIA EMAIL ( and First Class Mail uan Pablo Molyneux Molyneux Studio, Ltd. c/o Jay Goldberg, Esq. 250 Park Avenue Suite 2020 New York, New York 10177 Re: Agreement for Design Services dated May 1
Entities connected to both Jeffrey Epstein and Pablo Molyneux
Darren Indyke
PERSONthe State of New York
LOCATIONFancelli
PERSONJuan Pablo Molyneux
PERSONJay Goldberg
PERSONJean Pierre Fancelli
PERSONStudio
PERSON