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

abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (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 al

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

abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t

. 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

abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t

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

s services included, among other things, the design, as well as the delivery and installation of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry") for the library in the Office Pavilion. Molyneux's design for the library of the Office Pavilion, as agreed to by Epstein, required that the Libr

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

abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN I JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., and ATELIER FANCELLI, Defendants. ) ) ) CASE NO. ST-10-CV- ) ) ACTION FOR DAMAGE

AGES ) ) JURY TRIAL DEMANDED I ) ) COMPLAINT COME NOW, the Plaintiffs, Jeffrey Epstein and L.S.J., LLC (collectively referred to herein as "Epstein"), by and through their undersigned counsel, Hodge & Francois, and as and for their complaint against the Defendant, Fancelli Paneling, Inc., state

ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN I JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCE

on. 5,6. Molynewc's services included the design, as well as the delivery and installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry") for the library in the Office Pavilion. Molyneux's design for the library of the Office Pavilion, as agreed to by Epstein, required that the Libr