opportunity to serve interrogatories and requests for production on us. This particular Judge is a real stickler for complying with Court orders so Fancelli is going to have some problems. Please note that the scheduling order is attached and we are supposed to mediation this matter by December I, 2011

t Fancelling Paneling has missed the October 15, 2011 deadline for filing its Rule 26(a) Initial Disclosures. If we want Court intervention to make Fancelli file, then we first have to write to Fancelli and ask them to comply and/or meet and confer as to an agreed upon date when they expect to comply. I

s what Fancelli is now referring to as the September 8 punchlist. If that is the case, please confirm that it contains all of the work to be done by Fancelli, so we can formalize an agreement, or whether we can even use it as the punchlist to be included with additional, new work to be agreed upon. Thank

ct: Re: stj - cpstcin SEPT 8th Punch list Importance: High For Settlement Purposes Only - Without Prejudice Donna, In addition to the work on what Fancelli refers to as the September 8 punch list, I understand that the following are also to be properly addressed and corrected: The sliding window shutte

opportunity to serve interrogatories and requests for production on us. This particular Judge is a real stickler for complying with Court orders so Fancelli is going to have some problems. Please note that the scheduling order is attached and we are supposed to mediation this matter by December I, 2011

neling has missed the October 15, 2011 deadline for filing its Rule 26(a) Initial Disclosures. If we want Court EFTA00425454 intervention to make Fancelli file, then we first have to write to Fancelli and ask them to comply and/or meet and confer as to an agreed upon date when they expect to comply. I

opportunity to serve interrogatories and requests for production on us. This particular Judge is a real stickler for complying with Court orders so Fancelli is going to have some problems. Please note that the scheduling order is attached and we are supposed to mediation this matter by December I, 2011

t Fancelling Paneling has missed the October 15, 2011 deadline for filing its Rule 26(a) Initial Disclosures. If we want Court intervention to make Fancelli file, then we first have to write to Fancelli and ask them to comply and/or meet and confer as to an agreed upon date when they expect to comply. I

celli holds itself out as skilled in intricate wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork. In fact, Fancelli's website advertises that Fancelli's "[learn of artisans, sculptors and cabinet makers uphold the tradition and carry on the sophisticated art of fi

as to be properly installed on Little Saint James Island, and the staining and finishing were to be completed. 8. Between May 2009 and March 2010, Fancelli proceeded to install the Library Cabinetry on Little St. James Island. As of the date of this Affidavit, however, Fancelli has failed to fully comp

Please advise how you want me to handle. If Fancelli and Molyneux resolved their issues, why are we providing a list? I would like to tell her that Fancelli and Molyneux met last week and resolved all their issues regarding the punch list, which I sent to you (Donna Glasgow) in August. As to service of p

t 7:22 PM Subject: Fwd: epstein/little st james/fancelli To: Jeevacation Epstein [email protected]> Please advise how you want me to handle. If Fancelli and Molyneux resolved their issues, why are we providing a list? I would like to tell her that Fancelli and Molyneux met last week and resolved all

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.

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

From: Darren Indyke < To: Lesley Groff <1 Subject: Re: Meet w/MJ before Fancelli meeting? Date: Tue, 27 Nov 2012 15:18:04 +0000 Please make the arrangements with Experton and confirm for me that you have done so. Thanks, Lesley.

wrote: Yes 30 minutes Sent from my iPad On Nov 27, 2012, at 9:39 AM, Lesley Groff < > wrote: Per Darren...would you like to meet w/MJ before the Fancelli meeting? EFTA00400936 EFTA00400937

ications, discussions, information or materials in any papers served or filed in the Litigation or in any other litigation. 4. Each of Epstein and Fancelli acknowledges that, unless otherwise decided in the course of the Meeting and accepted in writing by both parties, (a) the only thing which can be m

ncelli Paneling, Inc. ("Fancelli"), with respect to the communications, discussions, information and materials that may be exchanged by Epstein and Fancelli in front of their respective attorneys during the meeting to take place between them on Monday, December 3, 2012, at 11:00AM at the offices of Mait

t Fancelling Paneling has missed the October 15, 2011 deadline for filing its Rule 26(a) Initial Disclosures. If we want Court intervention to make Fancelli file, then we first have to write to Fancelli and ask them to comply and/or meet and confer as to an agreed upon date when they expect to comply. I

opportunity to serve interrogatories and requests for production on us. This particular Judge is a real stickler for complying with Court orders so Fancelli is going to have some problems. Please note that the scheduling order is attached and we are supposed to mediation this matter by December I, 2011

w/MJ before Fancelli meeting? Date: Wed, 28 Nov 2012 21:59:36 +0000 Looks like JE already told you yes that he would meet MJ 30 minutes before the Fancelli meeting. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor, New York, New York 10022 Telephone: Telecopier: Mobile: ema

From: Darren Indyke < To: Lesley Groff Subject: Fwd: Meet w/MJ before Fancelli meeting? Date: Wed, 28 Nov 2012 21:59:36 +0000 Looks like JE already told you yes that he would meet MJ 30 minutes before the Fancelli meeting. DA

06, 1408 (3d Cir. 1991). In its Memorandum Opinion dated May 16, 2011, however, the Court stated: C. The Court Will Not Dismiss the Matter Based on Fancelli's Defense of 3 See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989) See Leuthner v. Blue Cross & Blue Shield of Northeastern Pa., 454 F.3d 120 (3d

acceptance of Fancelli's obligations arising from the Purchase Order. In short, the benefits due Molyneux were accepted and approved by Molyneux. If Fancelli satisfied its obligation to Molyneux under the Purchase Order, then these is no unfulfilled "promised performance" to be enforced by Plaintiffs, as

al roofing topcoat paint - Contract out to Bluestone Services. Work is 50% completed. ■ Millwork installation completed with the crew they have. Mr. Fancelli arrived to inspect the work. Meeting on site Saturday 6/20/09 with Fancelli, Molyneux and Doug Schoettle. Awaiting direction. IV. Fit up, Finish a

mpleted. ■ Millwork installation completed with the crew they have. Mr. Fancelli arrived to inspect the work. Meeting on site Saturday 6/20/09 with Fancelli, Molyneux and Doug Schoettle. Awaiting direction. IV. Fit up, Finish and Envelop work: ■ EIFS scope being revised- plans and specifications for r

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 y

EXHIBIT B I 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 not cost to you. This means that you will not be responsible for any Fancelli installer expenses including travel,

ou, but not sure it went through...we have been having internet problems...so wanted to email again. > Darren is asking if there are any updates on Fancelli regarding Boyson? Darren is getting a lot of push back from Jeffrey. > • Please let me know. > • Thanks, > Lesley > Assistant to Jeffrey Epste

. On Oct 19, 2011, at 12:55 PM, wrote: > I have been stuck in St Croix for the last 2 days witht deposition. Will be in St X tomorrow as well. In Fancelli, our Rule 26(a) Initial Disclosure Statement was served on Fancelli's attorneys on Oct 17th by mail. They were due on Oct 15th which was a Saturday

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

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

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,

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

as to be properly installed on Little Saint James Island, and the staining and finishing were to be completed. 8. Between May 2009 and March 2010, Fancelli proceeded to install the Library Cabinetry on Little St. James Island. As of the date of this Affidavit, however, Fancelli has failed to fully comp

celli holds itself out as skilled in intricate wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork. In fact, Fancelli's website advertises that Fancelli's "[learn of artisans, sculptors and cabinet makers uphold the tradition and carry on the sophisticated art of fi

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

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

so I (we) can resolve this. Tomorrow is a holiday in Europe, so I will call you Tuesday, I have someone in mind. I will continue though trying with Fancelli. J.P. Sent from my iPad On Oct 30, 2010, at 8:52 PM, Jeffrey Epstein < > wrote: consider hiring someone else to finish *************************

empt to promise something instead On Sun, Oct 31, 2010 at 12:51 PM, < > wrote: You see, I'm working for a solution that could be even better than Fancelli and you cut my wings. I don't understand you. Sent from my BlacicBerry@ wireless device From: Jeffrey Epstein <[email protected]> Date: Sun, 3