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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, FANCELLI PANELING, INC., Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED MOTION FOR ENLAR
OLL III.. ORDERED THAT DEFENDANT FANCELLI PANELING, INC.'S JANUARY 13, 2011 MOTION TO DISMISS IS DENIED; AND IT IS FURTHER ORDERED THAT PLAINTIFFS JEFFREY ESPSTEIN AND L.S.J., LLC, MUST JOIN AS A PARTY TO THIS ACTION MOLYNEUX STUDIO AND. TO THAT END, MUST FILE A SECOND AMENDED COMPLAINT WITHIN FOURTEEN 14 DAYS
and incorporated herein. EFTA00309172 Motion for Enlargement of Time to File Motion for Reconsideration of Order to Joint Molyneux Studio, Ltd. Epstein vs. Fanceili Paneling, Inc. Civil No. ST-10-O4443 4. The undersigned counsel's office has either an office employee or an independent courier che
es S. Carroll III CASE TYPE: DAMAGES - CIVIL SECONDARY null PETITION PARTY NAME LITIGANT PARTY TYPE L.S.J., LLC , P002 PLAINTIFF EPSTEIN , JEFFREY P001 PLAINTIFF FRANCOIS ESQ., DENISE M P001 ATTORNEY FOR ANY OTHER PARTY FANCELLI PANELING, INC., D001 DEFENDANT MOORE , TRESTON E. D001
ME NOW the Plaintiffs, Jeffrey Epstein and L.S.J., LLC, by and through their undersigned counsel, Hodge & Francois, and move this Court, pursuant to Super. Ct. R. 10(a)(2) and LRCi 7.3 for an enlargement of time within which to file Plaintiffs' motion for reconsideration of this Court's Order, entered May
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-I 0-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED 0N.) PLAIN
was essentially a motion, will also be addressed below. EFTA00308339 Plaint10' Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Fanelli Paneling. Inc. Case No. ST-10-CV-443 I. PROCEDURAL HISTORY. On March 4, 2011 Plaintiffs and Defendant filed a Stipulation to Ex
ummary Judgment. Respectfully submitted, HODGE AND FRANCOIS Dated: 3129 (2-01 1 By: Denise Francois aLcusiki Tel. Fax. ( Emai Attorneys for Jeffrey Epstein and L.SJ., LLC 8 EFTA00308346 Plaintiffs' Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Fancelli Panelin
GIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCE
Defendant to file its Reply to Plaintiff's Opposition to Defendant's Motion to Dismiss after the expiration of the specified period as required by Super. Ct. R. 10(a)(2), nor do the multiple motions and letter justify the filing of an Amended Reply. Defendant's Amended Reply was filed in violation of LR
. . . . . . . . . . . . . . . IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., ) ) ) Plaintiffs, ) ) v. ) NO. ST-10-CV-443 ) FANCELLI PANELING, INC., ) ) (CARROLL, J.) Defendant. ) OPPOSITION TO MOTION
ourt held that: EFTA00308324 ii Ii iI In the Factual and Procedural Background section of the Memorandum Opinion, the Court noted that in 2005 Epstein contracted with non-parties — "J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")" — to design a residential project on
rt of the Virgin Islands, bearing the Case No. 3:10-cv-00034, captioned 4 EFTA00308327 J.P.Molyneux Studio, Ltd. and Juan Pablo Molyneux against Jeffrey Epstein and L.S.J. LLC. (the "Molyneux Action'), in which Molyncux alleges: [s]ubsequent to the execution of the Design Services Agreement, Plaintiffs, wi
IRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., ) ) ) Plaintiffs, ) ) v.
to the contrary). 5. For our limited purposes to point, the only Superior Court Rule arguably contrary to Fed. R. Civ. P. 1-19 and LRCi 1-12.1, is Super. Ct. R. 9, excluding intervening weekends and holidays from the calculations for periods of eleven (11) days or less.2 6. The Court's Memorandum Opinio
Entities connected to both Jeffrey Epstein and Super. Ct
Juan Pablo Molyneux
PERSONthe Superior Court
ORGANIZATIONTreston E. Moore
PERSONMOORE DODSON & RUSSELL
ORGANIZATIONU. S. Mail
LOCATIONMolyneux Studio, Ltd.
ORGANIZATIONFRANCOIS
LOCATIONOpposition to Motion
ORGANIZATIONJuan Pablo
PERSONJ. P. Molyneux Studio
PERSON