Epstein Secrets

Paneling, Inc., from a name sounding to me like "Charles Oregario." stating that he was a potential client

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

n, but Fancelli has not. As it considers Rule 13 CHARLES ALAN WRIGHT & Alumna It MILLER, FEDERAL PRACTICE

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

010 ) Court Date: at I AFFIDAVIT OF SERVICE I, CHARLES GUERRIERO, being duly sworn deposes and says depo

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.

te courts the burden of unnecessary proceedings. Charles E Daley, 799 F.2d 343, 348 (7th Cir. 1986). III.

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

1.00804-0310 'Freston E. Moore J. Daryl Dodson Charles S. Russell, Jr. Michele Baker Telephone Facsim

nversation with Mr. Fanelli and his French Attorney regarding your letter to me dated September 10, 2012, which we forwarded to them yesterday. Mr. Fancelli's comments pertaining to the discussion you referenced therein differs in several respects. called Mr. Fancelli speaking French, but he could hear

te courts the burden of unnecessary proceedings. Charles v. Daley, 799 F.2d 343, 348 (7th Cir. 1986). Thi

wood paneling for the library of the Office Pavilion (the "Library Cabinetry"). Under third party beneficiary status, Plaintiffs filed suit against Fancelli for breach cn EFTA00307562 MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER ENTERED MAY 24, 2011 Epstein e

Paneling, Inc., from a name sounding to me like "Charles Gregario," stating that he was a potential client

al project - a library - in mind. He seemed vague as to details, so I asked him to send plans. He said he did not have any, but wanted to visit the Fancelli showroom. I set an appointment with him for November 29, 2010 at 5:3015. 4. On November 29, 2010, Charles Oregano called again to make sure that I