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y, 2009, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux")), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have arisen between Molyneux, on the one hand, and LSJ and Epstein, on the other hand, relating to payments and deli
ong Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux")), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have arisen between Molyneux, on the one hand, and LSJ and Epstein, on the other hand, relating to payments and deliverables i
r with JP, "Molyneux")), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have aris
n connection therewith, necessary for the proper installation, restaining and refinishing of the cabinetry already delivered to Little St. James by Atelier Fancelli (the "Covered Office Services"). (iv) Notwithstanding the provisions of Section 2(b)(iii) hereof, the parties acknowledge that the labor charges f
n connection therewith, necessary for the proper installation, restaining and refinishing of the cabinetry already delivered to Little St. James by Atelier Fancelli. (ii) Molyneux acknowledges and agrees that the occurrence of the Office Completion Date by January 1, 2010 is a material part of the considerati
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 for projects in the United States, and upon information and belief, Fancelli Paneling, Inc. acts through Atelier Fancelli for projects in Europe. Atelier Fancelli and Fancelli Paneling, Inc. are both collectively referred to herein as "Fancelli" as they both share the same principal, i.e. Jean-Pierre Fancelli
craft with the commitment to create spaces that reflect the perfect balance of harmony and timeless aesthetic." 3,4. Upon information and belief, Atelier Fancelli is Fancelli Paneling, Inc.'s affidiated company located in St. Ouen, France, and Atelier Fancelli acts through its new York corporation for project
ective Date"), by and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties"). WHEREAS, disputes have arisen between Molyneux and Studio, on the one hand, and LS
and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux and LSJ, the "Parties"). WHEREAS, disputes have arisen between Molyneux and Studio, on the one hand, and LS) and Epst
her with JP, "Molyneux,") LS.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein", and together with Molyneux a
Agreement or the Office Design Agreement, and nothing provided herein shall release Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any such Fancelli entity (collectively, the "Fancelli Group"), from any Claims whatsoever.
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 AFFIDAVIT
Francois, Esquire Epstein a at vs. Fancelli Paneling, Inc. Civil No. ST-le-CV-443 5. That paragraph 3(a) of the Confidential Agreement provides: Epstein and LSJ and each of their successors, assigns, principals, heirs, executors and administrators (collectively, the "Epstein Releasors") hereby fully
IRGIN ISLANDS DIVISION OF St THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCE
greement or the Office Design Agreement, and nothing provided herein shall release Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any Fancelli entity ("collectively, the "Fancelli Group"), from any Claims whatsoever. 6. T
Entities connected to both Jeffrey Epstein and Atelier Fancelli
Darren Indyke
PERSON
U.S. Virgin Islands
LOCATIONthe State of New York
LOCATIONFancelli
PERSONL.S.J.
ORGANIZATIONJuan Pablo Molyneux
PERSONJay Goldberg
PERSONJean Pierre Fancelli
PERSONStudio
PERSONThe Epstein Releasors
ORGANIZATIONthe "Fancelli Group
ORGANIZATIONMolyneux Releasors
ORGANIZATIONthe Molyneux Releasees
ORGANIZATIONFancelli Studios
ORGANIZATION