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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
TA00309187 Plaintiffs' Opposition to Defendant's Motion to Minim Epstein et al. n. Fancelli Paneling. Inc. Case No. ST- I 0-CV-443 B. Defendant Fancelli Paneling, Inc.'s Connections with the Territory are Sufficient to Satisfy Both the Virgin Islands Long-Arm Statute and Constitutional Due Process. The Virgin Islan
lialonancto aoiaaans 9698922 : fiq VIOS EFTA00307083 FOR PUBLICATION IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING, INC., Plaintiffs, Defendant. DENISE FRANCOIS, ESQ. Hodge & Francois 1340 Taameberg St. Thomas, U.S. V
2 is the sole member of Plaintiff L.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little
Renaissance exchanged phone calls, faxes and emalls with s in :Bd e8S:00 TT -1.2-90 HU373/120103 aolHudns 0690912 : fiq Was xed EFTA00307088 Jetey Epstein v. Fancelli Paneling Inc. Civil No. ST-10-CV-443 Memorandum Opinion Page 6 of II foreign corporation engages in reciprocal communications with a
GIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING,
G, INC., Defendant. ) ) ) ) WIDER AND NOW, for the reasons stated in the Memorandum Opinion issued today, it is hereby ORDERED that Defendant Fancelli Paneling, Inc.'s January 13, 2011 Motion to Dismiss is DENIED; and it is further ORDERED that Plaintiffs Jeffrey Epstein and L.S.J., LLC, must join as a party to th
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
itment 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 projects in the United States, and u
Entities connected to both Jeffrey Epstein and Fancelli Paneling, Inc.'s

Prince Charles
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATIONthe State of New York
LOCATION
St. John
LOCATIONFancelli
PERSON
Ashcroft
PERSONBertrand
PERSONJames Island
LOCATIONL.S.J.
ORGANIZATION
V.I.
LOCATIONV.I.C.
ORGANIZATION
Little St.
LOCATIONJean Pierre Fancelli
PERSONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONMolyneux Studio
ORGANIZATIONFRANCOIS
LOCATION
Metcalfe
PERSONthe "Library Cabinetry
ORGANIZATION
Falwell
PERSON