7
Shared Docs
7
Same-Page
7 / 14
Mentions
ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. . 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design ser
ated to conduct purposely directed at the forum state. Id. Defendant maintains that this Court lacks specific jurisdiction over it as well, because Fancelli does not have sufficient minimum contacts with the Virgin Islands to support the exercise of jurisdiction consistent with due process. See Int'l Sho
e and as may be developed through discovery. The reservation of rights was just that. V. CONCLUSION Plaintiffs Amended Complaint against Defendant Fancelli must be dismissed, with prejudice, for all, or any of the foregoing reasons. WHEREFORE, Defendant respectfully requests this Honorable Court to gr
alance due on the attached October 8, 2009 bill from Mr. Fancelli, as well as the attached $18,618.00 bill from Mr. Fancelli for his trip to Little Saint James in May/June 2009. As for any need that Mr. Molyneux to appear on the Island, we believe that has been satisfied by his three trips there, only to
FLOOR NEW YORK. NY 10177-0077 MEMORANDUM TO: Damn Indyke FROM: Jay Goldberg DATE: March 25, 2010 At the time of your e-mail stating that Mr. Fancelli was not on the Island, you were --- as in so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16
he library building is equipped with a state of the art system to condition the air inside the building. During the installation of the paneling by Fancelli, the exterior doors have been off their hinges and wide open the humid tropical air, and also the windows have been open, allowing humid air to ent
alance due on the attached October 8, 2009 bill from Mr. Fancelli, as well as the attached $18,618.00 bill from Mr. Fancelli for his trip to Little Saint James in May/June 2009. As for any need that Mr. Molyneux to appear on the Island, we believe that has been satisfied by his three trips there, only to
77 MEMORANDUM TICIENIONIC TELICCOPialna TO: Damn Indyke FROM: Jay Goldberg DATE: March 25, 2010 At the time of your e-mail stating that Mr. Fancelli was not on the Island, you were --- as in so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16
he library building is equipped with a state of the art system to condition the air inside the building. During the installation of the paneling by Fancelli, the exterior doors have been off their hinges and wide open the humid tropical air, and also the windows have been open, allowing humid air to ent
alance due on the attached October 8, 2009 bill from Mr. Fancelli, as well as the attached $18,618.00 bill from Mr. Fancelli for his trip to Little Saint James in May/June 2009. As for any need that Mr. Molyneux to appear on the Island, we believe that has been satisfied by his three trips there, only to
PHONIC main:J.6000 TaCCOMIM law via-sools TO: Damn Indyke FROM: Jay Goldberg DATE: March 25, 2010 At the time of your e-mail stating that Mr. Fancelli was not on the Island, you were --- as in so many other respects — mistaken. Several things are clearly beyond dispute: (1) I wrote you on March 16
he library building is equipped with a state of the art system to condition the air inside the building. During the installation of the paneling by Fancelli, the exterior doors have been off their hinges and wide open the humid tropical air, and also the windows have been open, allowing humid air to ent
nt. As stated above, this includes any action relating to the design and related services provided by Molyneux for Plaintiffs with respect to Little Saint James island and relating to the District Court lawsuit. 13 EFTA00307590 Memorandum in Support of Plaintiffs' Motion for Reconsideration Epstein et a
ideration Epstein et at vs. Fancelli Paneling, Inc. Case No. ST-I 0-CV443 "Library Cabinetry"). As third party beneficiaries of that contract with Fancelli, Plaintiffs filed suit against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was i
against Fancelli for breach of contract and negligence because the Library Cabinetry is defective and its installation was improper and incomplete. Fancelli was served with the Summons and First Amended Complaint on December 3, 2010. On December 30, 2010, Plaintiffs and JP and Molyneux entered into a co
O ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design ser
st to you. This means that you will not be responsible for any Fancelli Installer expenses including travel, lodging, food, incidentals, etc. After Fancelli finishes the Installation., I will decide if the color of the paneling is adequate for the overall ambiance. If It Is not, I will select color with
Request Riplace bamboo mash at all cabinet dos* with metal mesh In a dark color that will not rust. Status: New metal grilles are not in agreement 'Fancelli has repaired damaged grilles and will provide 8 new framed grilles for future use. 01901 — Punch List — Item #10 ••••••••••••616 • • Damaged bam
O ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design ser
st to you. This means that you will not be responsible for any Fancelli installer expenses Including travel, lodging, food, incidentals; etc. After Fancelli finishes the Installation, I will decide if the color of the paneling is . adequate for the overall ambiance. If it Is not, I will select color with
l refer to Jeffrey Epstein. propose to include all of the following services and items for the $250,000 that we have agreed: The Office/ Library: Fancelli will complete the installation at no cost to you. This means that you will not be responsible for any Fancelli installer expenses Including travel,
Entities connected to both Saint James and Fancelli

Jeffrey Epstein
PERSONBrice Gordon
PERSONDarren Indyke
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
Condoleezza Rice
PERSON
Lesley Groff
PERSON
U.S. Virgin Islands
LOCATIONLarry Visoski
PERSON
New York
LOCATIONGary Kerney
PERSON
George W. Bush
PERSONDoug Schoettle
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONLeon Black
PERSONTOM MELNICK
PERSON
St Thomas
LOCATIONL.S.J.
ORGANIZATION
Woody Allen
PERSON