Epstein Secrets

trict Court of the Virgin Islands for damages sustained as a result of the loss of their goods. After finding that Ocean-Air's activities within the Virgin Islands constituted transacting business within the Territory and contracting to supply services or things in this Territory within the meaning of subsectio

LANDS ARE THE CORRECT FORUM FOR PLAINTIFFS' CAUSES OF ACTION AGAINST DEFENDANT. Ignoring the facts that: Plaintiff Jeffrey Epstein is a resident of the United States Virgin Islands with his home on Little Saint James Island; L.S.J., LLC, which is solely owned by a United States Virgin Islands resident and maintains its principa

fs' FAC, the factual allegations of which must be accepted as true and construed in the light most favorable to the Plaintiffs, clearly establishes the Virgin Islands' overwhelming local interest in this controversy. The controversy is of local interest in the Virgin Islands and localized interest rests with the V

ended by Studio and Fancelli when they contracted that the Library Cabinetry was to be installed and used in an office/library structure located in the United States Virgin islands and would be therefore subject to temperature and humidity levels inherent in a Caribbean climate, as well as within an office structure in

to Mr. Jean Pierre Fancelli. 5 In addition, Defendant specifically informed Plaintiffs' counsel, Darren lndyke, that because of limitations with Mr. Fancelli's ability to communicate in English, Mr. lndyke should communicate with Mr. Fancelli through Mr. Barthod . Pl. Ex. 3 Thus, Mr. Barthod has been pre

Ex. 4. In support of its argument for insufficient service of process, Defendant asserts that the ...Summons and Complaint (sic) were delivered to Fancelli's office in New York on or about November 29, 2010 and left at that location with an unauthorized employee of Fancelli Paneling, Inc." However, Mr.

Paneling Inc. Civil No. ST-10-CV-443 Memorandum Opinion Page 2 of 11 FACTUAL AND PROCEDURAL BACKGROUND Plaintiff Jeffrey Epstein, a resident of the Virgin Islands,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, E

nstallation of the cabinets, in performance of its contract with Molyneux, were to benefit Epstein and L.S.J., and would be used in a library in the Virgin Islands.' On July 30, 2010, Plaintiffs filed the Complaint in this action, alleging that the cabinetry installation had not been properly completed, that t

iction is proper under section 4903(a)(2). All that is required to satisfy section 4903(a)(2) is that a "contract be performed, at least in part, in the virgin Islands and that the cause of action arise out of the contract."31 If a defendant knows that the ultimate destination of its goods will be the Virgin Island

and that venue is improper.' e Court finds that Fancelli conducted business and contracted to supply services or things in 's Territory. Therefore, Fancelli is subject to the Court's jurisdiction. In addition, the Court ds that Plaintiffs have pleaded a sufficient claim for breach of a third-party benefi

Amended Complaint, arguing, among other things, that Plaintiffs' service of process was insufficient that the Court lacks personal jurisdiction over Fancelli; that Plaintiffs do not state a laim for relief; that Plaintiffs have failed to join a necessary party; and that venue is improper.' e Court finds

mation and belief, the remaining Defendant, L.S.J., LLC, is organized in the State of Delaware and maintains its principal place of business within the U.S. Virgin Islands. 5. This Court has original jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000, exclu

e with the laws of the Virgin Islands applicable to agreements entered Into entirely within the Virgin Islands, without regard to the principles of Virgin Islands' law regarding conflicts of ;mks. 19. Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the

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

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 services for the residential compound Epstein was c

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

rmation and belief, the remaining Defendant, L.SJ., LLC, is organized in the State of Delaware and maintains its principal place of business within the U.S. Virgin Islands. 5. This Court has original jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000, exclu

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,

eux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island in St. Thomas, U. S. Virgin Islands. As part of this project, Epstein contracted with Molyneux to design the interior and exterior of a separate building on Little Saint James Island k

ork, which is engaged in the business of restoration and reproduction of antique wood panels and cabinetry in the United States, Canada and Europe. Fancelli's website at http://www.fancelli-paneling.com advertises Jean- Pierre Fancelli as a master of his craft, trained as an architect who "works directly

as set the jury selection and trial in this matter for December 3, 2012. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EXHIBIT 1 EFTA00602425 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 26W Epstein. et al. v. Fancelli Paneling. Inc., et al. Page 4 Re

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shalhout, Docket Nos. 12-1076 & 12-1077. EXHIBIT 1 EFTA00602424 AMENDED

as set the jury selection and trial in this matter for December 3, 2012. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EFTA00614298 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 260) Epstein, et al. v. Fancelli Paneling, Inc., et al. Page 4 Respectfully

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shalhout, Docket Nos. 12-1076 & 12-1077. EFTA00614297 AMENDED NOTICE OF M

has set the final pretrial conference for November 9, 2012 at 9:30 a.m. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EFTA00616775 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 260) Epstein, et aL v. Fancelli Paneling, Inc., et aL Page 4 7. The Court

nce of good cause shown, counsel with cases before the Court are expected to be available for oral argument during that week. Counsel for Defendant Fancelli is before that Court on that occasion in the matter of United States v. Shaihout, Docket Nos. 12-1076 & 12-1077, recently confirmed for oral argume

S JURY TRIAL DEMANDED AFFIDAVIT Denise Francois, after being duly sworn deposes and says: 1. That I am an attorney authorized to practice law in the United States Virgin Islands, and a partner in the law firm of Hodge & Francois, legal counsel of record for the Plaintiffs Jeffrey Epstein and L.S.J., LLC (the "Plaintiffs") in

elease Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any Fancelli entity ("collectively, the "Fancelli Group"), from any Claims whatsoever. 6. That paragraph 4(a) of the Confidential Agreement provides: The Epste