Epstein Secrets

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) Plaintiffs, vs- ) ) ) CASE NO. ST-10-CV-443 ACTION FOR DAMAGES C • ) C; C I FANCELLI PANELING, INC., ) ) JURY T

. The FAC was properly served at the Defendant's correct business address on EFTA00309181 Plalnr f s' Opposition to Defendant's Motion to Dismiss Epstein et al. VS. Fanelli Paneling. Inc. Case No. ST-10-CK443 Defendant's President in care of Christian Barthod, who has previously acted as the Presiden

epaid on this 11'" day of February, 2011. bb K1/4 BRAD. 4 C( 30 EFTA00309210 Superior Court of the Virgin Islands - Division of St. Thomas - St. John JEFFREY EPSTEIN AND L.S.J., LLC Plaintiff v. FANCELLI PANELING, INC. Defendant STATE OF New York. COUNTY OF Nassau ss: ) Index No.: ST-10•CIV-443 ) Filing Da

RGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) Plaintiffs, vs-

wholly owned by a Virgins Island resident (i.e., Mr. Epstein), maintains its principal address in the Virgin I

on (the "Library Cabinetry"). My design concept for the library of the Office Pavilion, as agreed to by Mr. Epstein, was inspired by the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of the concept of the library at El Escorial

Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studi

Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studio would de

State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective com

s the Office Pavilion. 4. In consultation with Mr. Epstein, I created the conceptual design, including cabi

to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es

. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studi

Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studio would de

State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective com

s the Office Pavilion. 4. In consultation with Mr. Epstein, I created the conceptual design, including cabi

to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es

DS DIVISION OF ST. THOMAS AND ST. JOHN J. P. MOLYNEUX STUDIO, LTD. and ) JUAN PABLO MOLYNEUX, ) ) Plaintiffs, ) Civil No. 2010/34 v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) DEFENDANTS' LRCi 16.1 DISCOVERY MEMORANDUM The Defendants Jeffrey Epstein and L.S.J., LLC (the "Defendants")

ted September 16, 2010: 1. Brief statement of facts underlying the claims or defenses in the action and of the legal issues in the case: In 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-str

for Design Services required Molyneux to credit defendant Epstein for $250,000 "to be applied against future servi

) Plaintiffs, ) Civil No. 2010/34 v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) D

o be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. Molyneux also presented Epstein with Molyneux's own 1 EFTA00725567 Defendants' Discovery Memorandum J.P. Molyneur Studio, Ltd. vs. Ep

pril 15, 2010 Re: Agreement for Design Services dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein (the "Design Services Agreement") Gentlemen: Pursuant to Section 7 of the Design Services Agreement, this letter constitutes notice, on behalf of

e "Design Services Agreement") Gentlemen: Pursuant to Section 7 of the Design Services Agreement, this letter constitutes notice, on behalf of Mr. Epstein and L.S.J., LLC, of your numerous breaches of the Design Services Agreement. Pursuant to Section 5 of the Design Services Agreement, it is a materi

ux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein (the "Design Services Agreement") Gentle

nt, this letter constitutes notice, on behalf of Mr. Epstein and L.S.J., LLC, of your numerous breaches of th

ndard condition. The cabinetry, invoiced at $780,000, was to be a custom built fine reproduction of the elegant antique cabinetry in the library of El Escorial in Spain. Mr. Epstein and you agreed on the cabinetry based, in part, on a rendering you provided to Mr. Epstein. As clearly indicated in the rende

P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studi

, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agreement whereby, among other things, I and Studio would de

e State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective com

s the Office Pavilion. 4. In consultation with Mr. Epstein, I created the conceptual design, including cabi

to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es

settlement discussions and communications, and shall not be admissible for any purposes in any litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneux Studio, Ltd., among others. Please be advised that nothing provided by this letter is intended o

litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneu

ame, frustrating every attempt by Mr. Epstein to achieve the required result The cabinetry was to be an exact copy of cabinetry from the library in El Escorial, the historic residence of the King of Spain. More than two years ago, when Mr. Molyneux met with Mr. Epstein in Paris to view a proposed sample of