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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- 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
in which the beneficiary is a party, the courts uniformly reject the argument that all of the original panics to the contract must be joined. Id., Schulman v. J.P. Morgan Investment Management. Inc., 35 F.3d 799, 807 n. 13, (C.A. 3d, 1994), and Gomer v. Philip Morris, Inc. 106 F. Supp, 2d 1262, 1266 (D.
Investigators with the New Mexico Attorney General's Office plan to turn over any information they gather about alleged sex crimes committed here by Jeffrey Epstein to federal prosecutors "as soon as possible," a spokesman for the AG says. That means that for now, Attorney General Hector Balderas' team is workin
for now, Attorney General Hector Balderas' team is working as fact-gatherer for the US Attorney's Office in the Southern District of New York, where Epstein pleaded not guilty last week to charges of sex trafficking of minors and sex trafficking conspiracy, says Matt Baca, senior counsel for Balderas' o
ather about alleged sex crimes committed here by Jeffrey Epstein to federal prosecutors "as soon as possib
irls when they were allegedly sexually abused by Mr. Epstein; other witnesses, including potential coconspirat
"Solution" To Encryption Is No Solution. In an op-ed in Just Security (7/18), Senior Policy Counsel at New America's Open Technology Institute Ross Schulman writes that the DOJ and FBI have repeatedly asserted that the extensive use of online communications apps "hampers their ability to conduct investig
investigation." Attorneys Seek Bail For Ghislaine Maxwell. The AP (12/7, Neumeister) reports from New York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part
nday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell'
New York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again s
ing to reclaim millions of dollars belonging to the government of Somalia from accounts frozen during the country's years of political turmoil. Now, Schulman is facing the possibility of decades in prison after the government accused him of defrauding the people he was claiming to help." Prosecutors "say
h-coronavirus-pandemic-brooklyn- elleabd1160c91d17a92b9d4792ae90a> (12/7, Neumeister) reports from New York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part
nday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Stemheim were made on Ghislaine Maxwell's
ew York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again se
ng to reclaim millions of dollars belonging to the government of Somalia from accounts frozen during the country's years of political turmoil. Now, Schulman is facing the possibility of decades in prison after the government accused him of defrauding the people he was claiming to help." Prosecutors "say
nvestigation." Attorneys Seek Bail For Ghislaine Maxwell. The AP (12/7, Neumeister) reports from New York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part
nday that her client, who again seeks release on bail, has lost weight and hair as she suffers under onerous jail conditions imposed in part because Epstein killed himself last year in a federal lockup." According to the AP, "The claims by defense attorney Bobbi Sternheim were made on Ghislaine Maxwell'
ew York, "A lawyer for the onetime girlfriend of Jeffrey Epstein said Monday that her client, who again se
ng to reclaim millions of dollars belonging to the government of Somalia from accounts frozen during the country's years of political turmoil. Now, Schulman is facing the possibility of decades in prison after the government accused him of defrauding the people he was claiming to help." Prosecutors "say
nian Natural Right," Ellen Frenkel, Fred Miller, Jeffrey Paul (eds.), Natural Law and Modem Moral Philos
tstein, I.S. (2007). The broken heart syndrome. Cleve Clin J Med, 74, Suppl 1, S17-22. 3. Wittstein, Thiemann, D.R., Lima, J.A., Baughman, K.L., Schulman, S.P., Gerstenblith, G., Wu, K.C., Rade, J.J., Bivalacqua, T.J., & Champion, H.C. (2005). Neurohumoral features of myocardial stunning due to sud
inian Natural Right,” Ellen Frenkel, Fred Miller, Jeffrey Paul (eds.), Natural Law and Modern Moral Philoso
tein, I.S. (2007). The broken heart syndrome. Cleve Clin J Med, 74, Suppl 1, 817-22. 3. Wittstein, I.S., Thiemann, D.R., Lima, J.A., Baughman, K.L., Schulman, S.P., Gerstenblith, G., Wu, K.C., Rade, J.J., Bivalacqua, T.J., & Champion, H.C. (2005). Neurohumoral features of myocardial stunning due to sudden
Entities connected to both Jeffrey Epstein and Schulman

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Boris Nikolic
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Eric Trump
PERSON
George Mitchell
PERSONDaphne Wallace
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Lawrence Krauss
PERSON
Condoleezza Rice
PERSON
Harry Reid
PERSON
Stephen Hawking
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Tom Pritzker
PERSON