Epstein Secrets

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

ant. ) COMPLAINT Plaintiffs, J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant, Jeffrey Epstein, by their attorney Rosh D. Alger, herein allege: I. Plaintiff, J.P. Molyneux Studio, Ltd. is a corporation organized and existing under the laws of the State of New York and mainta

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

g for parties and counsel who are Filing Users and through the alternate method indicated below for any party or counsel who is not a Filing User. Rosh D. Alger, Esquire Rosh D. Alger, Esquire, LLC PMB 10 Royal Dane Mall #12 St. Thomas, VI 00802 Tel: Fax: via: CM/ECF MI Mail K I Fax K i Hand Delivery K

unswom affidavit inaccurately state the status of settlement negotiations between the above-captioned parties. Based upon the attached Affidavit of Jeffrey Epstein ("Epstein") filed in support of this opposition and for the reasons set for the below, the Defendants' motion asking this Court to "withhold its rul

naccurately state the status of settlement negotiations between the above-captioned parties. Based upon the attached Affidavit of Jeffrey Epstein ("Epstein") filed in support of this opposition and for the reasons set for the below, the Defendants' motion asking this Court to "withhold its ruling on Def

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

declarant before an officer authorized to administer oaths." Black's Law Dictionary (9th ed. 2009). The statement submitted by Plaintiffs' counsel Rosh D. Alger does not comply with V.I. Code Ann. tit. 5, §699 which also requires affirmations to be sworn statements of truth nor does it comply with Title 28

HE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. MPOLYNEIJX STUDIO, LTD. and ) JUAN PABLO MOLYNEUX, ) ) Plaintiffs, ) ) v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) Case No.3:10-cv-00034 NOTICE OF MOTION COME NOW the Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Mo

NEUX, ) ) Plaintiffs, ) ) v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) Case No.3

BLO MOLYNEUX, ) ) Plaintiffs, ) ) v. ) ) JEFFREY EPSTEIN and L.S.J., LLC, ) ) Defendants. ) C

Case No.3:10-cv-00034 NOTICE OF MOTION COME NOW the Plaintiffs J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, by and through their counsel, Rosh D. Alger, and move this Court to exercise its discretion in the interests of justice by withholding its ruling on the Defendants' motion to dismiss, on the

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

parties is warranted pursuant to 28 U.S.C. § 2201. Defendants' motion should 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. Th

010 In connection with my request for you to send Rosh D. Alger a Rule 11 letter, you have asked me to provide you with some background relating to Jeffrey's claims against Mr. Molyneux which lead to the improper filing of Molyneux's complaint in the United States District Court of the Virgin Islands.

hed with a dark walnut stain and a wax finish and then installed in the library of the office pavilion on the Island. At the time that Molyneux and Epstein began settlement negotiations three years later, the finished cabinetry still had not been delivered to the Island. The cabinetry was to be an exac

ren Indyke RE: Molyneux Complaint in the District Court of the Virgin Islands DATE: April 14, 2010 In connection with my request for you to send Rosh D. Alger a Rule 11 letter, you have asked me to provide you with some background relating to Jeffrey's claims against Mr. Molyneux which lead to the imprope