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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
eates a duty in the promisor to any intended beneficiary to perform the promise, and the intended beneficiary may enforce the duty." KMART Corp. is Balfour Beatty, ha, 994 F.Supp. 634, 636 (D.V.I. 1998) (quoting Restatement (Second) q/' Contracts § 304). A third party beneficiary is an exception to the privit
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED MEMORANDUM IN SU
Fancelli for breach cn EFTA00307562 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein etab vs. Fanelli Paneling, Inc. Super. Cs Case No. ST-10-CV-443 of contract and negligence because the Library Cabinetry is defective and installat
RGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, FANCELLI P
(MI Sept 15, 1986). 5 EFTA00307566 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein el at vs Fencelli Paneling, Inc. Super. Ct. Case Na ST-ID-CV-443 Defendant offered no evidence that localizing any discovery request in the event of n
nd in place of the contracting party, Molyneux, to enforce their rights under the contract. Restatement (Second) of Contracts § 304; XMART Corp. v. Balfour Beatty, Inc., 994 F.Supp. 634, 637 a. 1998). Molyneux is not a necessary party because Plaintiffs stand in Molyneux's place and by reason of the Confident
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
and in place of the contracting party, Molyneux, to enforce their rights under the contract. Restatement (Second) of Contracts § 304; KMART Corp. v. Balfour Beatty, Inc., 994 F.Supp. 634, 637 (D.V.1. 1998). Molyneux is not a necessary party because Plaintiffs stand in Molyneux's place and by reason of the Conf
From: David Stern Sent: Monday, October 12, 2015 8:35 AM To: Jeffrey Epstein Subject: Re: Contractors Direct access to Top Management: Balfour Beatty (UK) http://www.balfourbeatty.com Implenia (Switzerland) http://www.i
bag (Austria) www.strabag.com <http://www.strabag.com> Bilfinger (Germany) www.bilfinger.com <http://www.bilfinger.com> On 11 Oct 2015, at 23:27, jeffrey E. <[email protected]> wrote: =orwarded message From: Mohamed Waheed <mailt > Date: Sun, =ct 11, 2015 at 10:55 AM Subject: Contractors To: "j
Waheed <mailt > Date: Sun, =ct 11, 2015 at 10:55 AM Subject: Contractors To: "jeffrey E." <[email protected] <mailto:[email protected]» Jeffrey. Hope all is well. Would you know an American or =uropean Company that would be interested to prequalify for large =onstruction projects in Kuwait.
: Monday, October 12, 2015 8:35 AM To: Jeffrey Epstein Subject: Re: Contractors Direct access to Top
From: David Stern Sent: Monday, October 12, 2015 8:35 AM To: Jeffrey Epstein Subject: Re: Contractors Direct access to Top Management: Balfour Beatty (UK) http://www.balfourbeatty.com Implenia (Switzerland) http://www.implenia.com Strabag (Austria) www.strabag.com <http://www.strabag.com> Bil
From: jeffrey E. <[email protected]> Sent: Monday, October 12, 2015 9:06 AM To: David Stern Subject: Re: Contractors mohamed is former presidnet of maldives
"_blank">jeevacation@gmail=com> wrote: Forwarded message From: Mohamed Waheed > Date:=Sun, Oct 11, 2015 at 10:55 AM Subject: Contractors To: "jeffrey=E." <[email protected] <mailto:[email protected]» Jeffrey. Hope all is well. Would you=know an American or European Company that would be inter
Mohamed Waheed > Date:=Sun, Oct 11, 2015 at 10:55 AM Subject: Contractors To: "jeffrey=E." <[email protected] <mailto:[email protected]» Jeffrey. Hope all is well. Would you=know an American or European Company that would be interested to prequalif= for large construction projects in Kuwait.
d is former presidnet of maldives , you =an deal directly On Mon, Oct 12, 2015 at 4:34 AM, David Stern &I wrote: Direct access to Top Management: Balfour Beatty (UK) http://www.balfourbeatty.com <http://www.=alfourbeatty.com> =div> Implenia (Switzerland) http://www.implenia.com chttp:=/www.implenia.com>
Entities connected to both Jeffrey Epstein and Balfour Beatty

Prince Charles
PERSON
New York
LOCATION
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Barack Obama
PERSONthe State of New York
LOCATION
New York State
LOCATION
St. John
LOCATIONFancelli
PERSON
Kuwait
LOCATIONCarney
PERSON
Malaysia
LOCATION
Waheed
PERSONJefferies
ORGANIZATION
Gibraltar
LOCATION
Mohamed Waheed
PERSON
Barron
PERSON
Horizon
ORGANIZATION
Zimbabwe
LOCATIONJuan Pablo Molyneux
PERSON