Epstein Secrets

New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about two important and time-sensitive issues which have arisen in connection with the performance of the Agreemen

your clients propose to deliver in satisfaction of their obligations under the Agreement for Design Services. By email dated November 24, 2009, Mr. Epstein advised Mr. Molyneux that the globe in the photograph was completely unacceptable. Mr. Molyneux and Mr. Epstein agreed that the globes to be deliv

eux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about t

sign Services. By email dated November 24, 2009, Mr. Epstein advised Mr. Molyneux that the globe in the photo

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to inform you about two important and time-sensitive issues which have arisen in connection wit

New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I wanted to make sure that you were up to date on the outstanding issues relating to the performance of the Agreement for Design Service

p to date on the outstanding issues relating to the performance of the Agreement for Design Services between our clients. On December 10, 2009, Mr. Epstein sent Mr. Molyneux the following email: "This will confirm t[wo] different globes„ you are to pick the color„ we still need the ceiling and shutter

eux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I wanted to make sure that yo

vices between our clients. On December 10, 2009, Mr. Epstein sent Mr. Molyneux the following email: "This wil

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I wanted to make sure that you were up to date on the outstanding issues relating to the performance of

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED MEMORANDUM IN SU

Fancelli for breach cn EFTA00307562 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein etab vs. Fanelli Paneling, Inc. Super. Cs Case No. ST-10-CV-443 of contract and negligence because the Library Cabinetry is defective and installat

RGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, FANCELLI P

(MI Sept 15, 1986). 5 EFTA00307566 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein el at vs Fencelli Paneling, Inc. Super. Ct. Case Na ST-ID-CV-443 Defendant offered no evidence that localizing any discovery request in the event of n

ion for reconsideration of this Court's Order entered on May 24, 2011 requiring Plaintiffs to file a Second Amended Complaint adding J. P. Molyneux Studio, Ltd. as a party on the grounds that such a forced joinder will create manifest injustice. For the reasons set forth below, the Plaintiffs' motion for rec

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF St THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED cr1 0 0 •

TRIAL DEMANDED cr1 0 0 • ist -:j • z MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF ORDER ENTERED MAY 24. 2011 Plaintiffs Jeffrey Epstein and L.S.J., LLC (collectively "Plaintiffs") submit this memorandum in support of their motion for reconsideration of this Court's Order entered on

lumns, and wood paneling for the Library in the Office Pavilion (the EFTA00307578 Memorandum in Support of Plaintiffs' Motion for Reconsideration Epstein et at vs. Fancelli Paneling, Inc. Case No. ST-I 0-CV443 "Library Cabinetry"). As third party beneficiaries of that contract with Fancelli, Plaintif

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

12 EFTA00307589 Memorandum in Support of Plaintiffs' Motion for Reconsideration Epstein et al vs. Fancelli Paneling, Inc. Case No. ST-IO-CV-443 Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J, LLC filed in the District Court of the Virgin Islands, Division of St. Thomas and St. John as

. . . . . . . . . . . . . . . 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., ) ) (CARROLL, J.) Defendant. ) OPPOSITION TO MOTION

ourt held that: EFTA00308324 ii Ii iI In the Factual and Procedural Background section of the Memorandum Opinion, the Court noted that in 2005 Epstein contracted with non-parties — "J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")" — to design a residential project on

rt of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned 4 EFTA00308327 J.P.Molyneux Studio, Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J. LLC. (the "Molyneux Action'), in which Molyncux alleges: [s]ubsequent to the execution of the Design Services Agreement, Plaintiffs, wi

IRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., ) ) ) Plaintiffs, ) ) v.

action formerly pending in the District Court of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned 4 EFTA00308327 J.P.Molyneux Studio, Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J. LLC. (the "Molyneux Action'), in which Molyncux alleges: [s]ubsequent to the execution o

New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to you in order to prevent what could soon become a breach by your clients of their obligations under the Design Services Agreem

spond. In addition, LSJ is awaiting oak wood samples with various stain or wax or other finish options for the final finishing for the woodwork for Jeffrey's review and approval. The woodwork as installed is not adequately finished, and under Exhibit B to the DSA, JP is obligated to "select the color w

d completed at the Office Pavilion by January 1, 2010 all of the items listed on Exhibit B hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010." We have been at a critical point in the completion of the Office Pavilion and JPs continuing and unex

250 Park Avenue Suite 2020 New York, NY 10177 Re: Design Services Agreement dated May 15, 2009 by and among Juan Pablo Molyneux, J.P. Molyneux Studio, Ltd., L.S.J., LLC and Jeffrey Epstein Dear Jay: I write to you in order to prevent what could soon become a breach by your clients of their obligations

ICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRICT COURT OF THE VIRGIN ISLANDS ) ) ss: DIVISION OF ST. THOMAS AND ST. CROIX ) AFFIDAVIT OF ROSH D. ALGE

S. Virgin Islands. 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. Subsequently, disputes arose between the parties with respect to the design services to be provided by Plai

Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRI

ld be denied. Dated: August 25, 2010 St. Thomas, U.S. Virgin Islands 5/ Rosh D. Alger Rosh D. Alger, Esq. Attorney for Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux VI Bar No.932 PMB 10 Royal Dane Mall #12 St. Thomas. VI 00802 Tel. Fax 5 EFTA00731231

so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complaints; (2) Elizabeth sent you an e-mail to the same effect on March 18 that two carpenters and two fin

n March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complain

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00605013 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE October 28, 2009 LITTLE ST. JAMES ISLAND JP

so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complaints; (2) Elizabeth sent you an e-mail to the same effect on March 18 that two carpenters and two fin

n March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complain

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00625040 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE LITTLE ST. JAMES ISLAND 6100 RED HOOK QUARTE

so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complaints; (2) Elizabeth sent you an e-mail to the same effect on March 18 that two carpenters and two fin

n March 16 that it was absolutely essential that Mr. Epstein be present on March 22 to deal with his complain

g these matters and not simply take the unsupported word of your client. Please advise your client that any further communications with JPMolyneux Studio, Ltd. shall be made solely with Ms. Kristen Goff. 4 EFTA00625047 .1. P. MOLYNEUX STUDIO LTD ALVIN WHITE LITTLE ST. JAMES ISLAND 6100 RED HOOK QUARTE