Epstein Secrets

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

s Agreement are valid and enforceable; and Awarding such other and further relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC • Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Roth D. Alger, Esq. VI Bar No. 932 P

RGIN ISLANDS' DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., * * * * * ) ) ) Plaintiffs,

MAR 1 4 2011I 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., ) ) Defendant. ) (CARROLL, J.) ) I DEFEND

t the outset that Plaintiffs' failed to reference the V.I. long-arm EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Def

00310020 03/10/11 11:1SAM HP LASF.RJET FAX p.02 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN * * * * * ) JEFFREY EPSTEIN, et al, ) ) Plaintiffs, ) v. ) NO. ST-I 0-CV-443 ) FANCELLI PANELING, INC., ) ) Defendant. ) (CARROLL,I) ) STATE OF NEW YORK ) COUN

reement are valid and enforceable; and d. Awarding such other and further relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Roth D. Alger, Esq. VI Bar No. 932 PMB

CIVIL NO. /2010 BREACH OF CONTRACT v. ) ) JEFFREY EPSTEIN, ) JURY TRIAL DEMANDED ) Defendant.

AS AND ST. JOHN ) J.P. MOLYNEUX STUDIO, LTD. and ) JUAN PABLO MOLYNEUX, ) ) Plaintiffs, ) ) CIVIL NO. /2010 BREACH OF CONTRACT v. ) ) JEFFREY EPSTEIN, ) JURY TRIAL DEMANDED ) Defendant. ) COMPLAINT Plaintiffs, J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant,

000 in the performance of their obligations under the contract. 8. From the start of plaintiffs' performance of the terms of the contract, defendant Epstein acted in bad faith and unfairly to unreasonably and successfully frustrate and obstruct plaintiffs' performance, making it impossible for plaintiff

ntiffs' performance of the terms of the contract, defendant Epstein acted in bad faith and unfairly to unreasonably

s. WHEREFORE, plaintiffs demand judgment in a sum no less than $300,000, together with interest, costs and disbursements. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorney for Plaintiffs Dated: 04/01/10 By: s/ Rosh D. Alger Rosh D. Alger Esquire VI Bar No. 932 PMB 10 Royal Dane Mall #12 St. Thomas,

case may be, as of the date of the day and year first above-written. J.P. MOLYNEITX STUDIO, LTD. •By: Juan Pablo Molyneux Pres • LO MOLYNEUX JEFFREY P.PSTEIN L.$.1.,LLC By: JEFFREY EPSTEIN Member EFTA00308319 Case: 3:10-cv-00034-CW-ITNIbifor ernent #: 83 Filed: 06/11/10(1PagerlQuisfenrit MOL,N1

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

Suit from my BlackBerry0 wireless device From: Jeffrey Epstein <jeevacationggmailcom> Date: 7:14:35-04

eement are valid and enforceable; and d. Awarding such other and fiirther relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Rosh D. Alger, Esq. VI Bar No. 932 Tel