Epstein Secrets

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

ument #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by and through the undersigned counse

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

EFENDANT IS SUBJECT TO INQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on

d States Virgin Islands applicable to agreements entered into entirely within the United States Virgin Islands, without regard to the principles of United States Virgin Island law regarding conflicts of laws. 18. Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the

THIS AGREEMENT, entered into this day of May, 2009, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux")), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, dis

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

erre Fancelli, and the actions of Fancelli Paneling, Inc. and Atelier Fancelli are indistinguishable. 4,5 In 2005, Epstein engaged the services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on

ux is a world-renowned interior designer. 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. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was const

cument #: 18 Filed: 08/25/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRICT COURT OF THE VIRGIN ISLANDS ) ) ss: DIVISION OF ST. THOMAS

y provide substantial grounds for civil claims against Mr. Molyneux and his firm, including, among other things, claims for fraud and violations of the Virgin Islands CICO statute. As I have informed you, Mr. Epstein intends to commence legal action in the Virgin Islands against Mr. Molyneux, his firm, and Fanceili, a

and communications, and shall not be admissible for any purposes in any litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneux Studio, Ltd., among others. Please be advised that nothing provided by this letter is intended or should be construed as a waiver

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

n the above-captioned action. 2. That I have personal knowledge of the matters set forth herein. 3. That on December 30, 2010, the Plaintiffs and Juan Pablo Molyneux and J. P. Molyneux Studio, Ltd. ("Molyneux) entered into a confidential Settlement Agreement and Release (the "Confidential Agreement") which, amon

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

ument #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS. DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.SJ., LLC. X PLAINTIFFS, by and through the undersigned counsel