EFTA01120429Set 9
2011-05-2437p2,724w
York engaged
in the business of restoration and reproduction of antique wood panels and cabinetry in the
United States, Canada and Europe. At all times relevant herein, Fancelli's website ... Molyneux's services included the design, as well as the delivery and
installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry")
for the library in the Office Pavilion ... library of the Office
Pavilion, as agreed to by Epstein, required that the Library Cabinetry was to be a reproduction
of the design, color, finish and proportions of the antique
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120429.pdf
EFTA00731209Set 9
8p1,893w
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 ... Molynewc's services included the design, as well as the delivery and
installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry")
for the library in the Office Pavilion ... library of the Office
Pavilion, as agreed to by Epstein, required that the Library Cabinetry was to be a reproduction
of the design, color, finish and proportions of the antique
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731209.pdf
EFTA00731251Set 9
7p3,082w
been very specific with Mr. Molyneux
regarding the look, proportions and finish of that cabinetry, and Mr. Molyneux has
continually deceived Mr. Epstein regarding the same, frustrating every attempt ... Epstein to achieve the required result The cabinetry was to be an exact copy of
cabinetry from the library in El Escorial, the historic residence of the King of Spain ... Epstein in Paris to view
a proposed sample of the reproduction of the cabinetry, Mr. Epstein observed that
the proportions of the sample were terrible and Mr. Epstein immediately
complained
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731251.pdf
EFTA00589459Set 9
8p2,166w
Office Pavilion.
4. In consultation with Mr. Epstein, I created the conceptual design, including
cabinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding
window shutters, for the library ... Office Pavilion (the "Library Cabinetry"). My design
for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library
Cabinetry was to be a reproduction ... design, color, finish and proportions of the antique
cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I
also provided to Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589459.pdf
EFTA02407959Set 11
9p2,188w
Office
Pavilion.
4. In consultation with Mr. Epstein, I created the conceptual design, including
cabinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding
window shutters, for the library ... Office Pavilion (the "Library Cabinetry"). My design for
the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library
Cabinetry was to be a reproduction ... design, color, finish and proportions of the antique
cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I
also provided to Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02407959.pdf
EFTA00722277Set 9
8p2,167w
Office Pavilion.
4. In consultation with Mr. Epstein, I created the conceptual design, including
cabinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding
window shutters, for the library ... Office Pavilion (the "Library Cabinetry"). My design
for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library
Cabinetry was to be a reproduction ... design, color, finish and proportions of the antique
cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I
also provided to Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722277.pdf
EFTA01071594Set 9
7p1,885w
Office
Pavilion.
4. In consultation with Mr. Epstein, I created the conceptual design, including
cabinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding
window shutters, for the library ... Office Pavilion (the "Library Cabinetry"). My design
concept for the library of the Office Pavilion, as agreed to by Mr. Epstein, was inspired by the
library at El Escorial ... Spain. I also provided to Mr. Epstein my own drawing of the
proposed Library Cabinetry. On the basis of the concept of the library at El Escorial, and my
drawings
https://www.justice.gov/epstein/files/DataSet%209/EFTA01071594.pdf
EFTA00728042Set 9
2010-04-145p2,098w
requirement to Jeffrey was for
Molyneux to deliver, install, restain and refinish the library cabinetry for the office
pavilion that was then under construction. Jeffrey contracted with Molyneux in
early ... have this cabinetry custom built and finished with a dark walnut stain
and a wax finish and then installed in the library of the office pavilion on the Island ... time that Molyneux and Epstein began settlement negotiations three years
later, the finished cabinetry still had not been delivered to the Island.
The cabinetry was to be an exact duplicate
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728042.pdf
EFTA00728406Set 9
2010-04-155p1,774w
obligations under the Design Services
Agreement Most significantly, you were required to cause the cabinetry for the
library of the Office Pavillion to be properly installed, restained, refinished and
completed ... many requests for you to correct the multiple problems and deficiencies
in the cabinetry, it remains in shoddy, defective and substandard condition.
The cabinetry, invoiced ... custom built fine
reproduction of the elegant antique cabinetry in the library of El Escorial in Spain.
Mr. Epstein and you agreed on the cabinetry based, in part
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728406.pdf
EFTA00725567Set 9
2010-09-165p1,243w
included, among other things, the design, as well as the delivery and
installation of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry") for
the library in the Office Pavilion ... library of the Office Pavilion, as
agreed to by Epstein, required that the Library Cabinetry was to be a reproduction of the design,
color, finish and proportions of the antique ... cabinetry, bookshelves, columns and wood paneling
of the library at El Escorial in Spain. Molyneux also presented Epstein with Molyneux's own
1
EFTA00725567
Defendants' Discovery Memorandum
J.P. Molyneur Studio
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725567.pdf
EFTA00307083Set 9
2011-05-2413p5,972w
turn, contracted
with Fancelli4 to have Fancelli construct some of the residence's library cabinetry.
Fancelli made the cabinets in Europe, shipping them in crates to Little St. James.
Plaintiffs ... state that Fancelli installed the cabinetry between May 2009 and March 2010.
According to Plaintiffs, Fancelli's agents were on Little St. James a number of times in order ... July 30, 2010, Plaintiffs filed the Complaint in this action, alleging that the cabinetry
installation had not been properly completed, that the finished products were defective, and that
Fiuicelli
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307083.pdf
EFTA01099088Set 9
2010-08-1021p5,745w
fact pattern:
Two New York companies contract in New York for the fabrication of cabinetry
in Europe that will be shipped to St. Thomas (by a third party) and installed ... Little St. James Island.
Defendant comes to Little St. James to see the cabinetry during installation and
returns after disputes arise for purposes of settlement.
Defendant respectfully submits that ... rely in asserting incomplete and defective
fabrication, installation, staining and finishing of the Library Cabinetry is directly and irrefutably
contradicted by court documents, contemporaneous e-mail transmissions, purchase orders, other
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099088.pdf
EFTA00727991Set 9
2010-03-242p767w
Dear Jay:
Fanceli has left the Island for a third time without finishing the cabinetry for
the Library. This time, at the eleventh hour, they claim that the humidity levels ... this will delay the project yet again for at least another two months.
The cabinetry has been installed in the Library since September of last year.
Mr. Molyneux's "expert ... order to properly finish the
cabinets. Although we have been discussing finishing the cabinetry on site since
before we reached our settlement almost 11 months ago, neither Fanceli
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727991.pdf
EFTA00761747Set 9
2010-03-242p770w
Dear Jay:
Fanceli has left the Island for a third time without finishing the cabinetry for
the Library. This time, at the eleventh hour, they claim that the humidity levels ... this will delay the project yet again for at least another two months.
The cabinetry has been installed in the Library since September of last year.
Mr. Molyneux's "expert ... order to properly finish the
cabinets. Although we have been discussing finishing the cabinetry on site since
before we reached our settlement almost 11 months ago, neither Fanceli
https://www.justice.gov/epstein/files/DataSet%209/EFTA00761747.pdf
EFTA00722592Set 9
2010-02-254p1,756w
eminently reasonable request for a written completion schedule
for the refinishing of the cabinetry. This request was intended to create a clear
timetable for the completion of the cabinetry ... communicated to you and Mr. Molyneux regarding, among other things, the lack of
adequate cabinetry finish, the globes, the guest desk chair, and the lack of an
adequate ceiling ... does require them to
complete the library.
As for the refinishing of the cabinetry, once again you are misinformed. Mr.
Epstein did not simply abruptly change his mind and request
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722592.pdf
EFTA00300053Set 9
2011-06-0711p2,708w
Defendant is a party and pursuant to which Defendant
fabricated and installed the subject cabinetry is a Purchase Order #2680 dated June 15, 2006,
between "MOLYNEUX" and Defendant, Fancelli Paneling ... which is as follows:
Woodworking FABRICATION & INSTALLATION of light oak
with waxed finish cabinetry per JPM design. Will include survey,
shop drawings, molding of base, lower cabinetry with doors ... Defendant
's
fabrication in light oak, fabrication design, stain color and installation of the cabinetry in
response to the Purchase Order is established by Molyneux's "Little St. James Punch
https://www.justice.gov/epstein/files/DataSet%209/EFTA00300053.pdf
EFTA02316065Set 11
2012-10-0310p2,552w
tribunal, the remaining provisions of the
Agreement shall not be thereby affected.
12. Cabinetry will be delivered direct to job site. All protection of job site floors and walls ... responsible for damages to unprotected surfaces. If job site is not able to receive cabinetry, Purchaser will be subject to storage
and redelivery charges to be specified by Change Order ... cabs must be stored, a total of 90% of Purchase Price for the
cabinetry 10% olus storage chargpi. payable Don delivery
Appro Date
Approved: Date
Bilotta
8NY/CON/9-1-09
EFTA
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02316065.pdf
EFTA00555767Set 9
2012-10-0310p2,596w
tribunal, the remaining provisions of the
Agreement shall not be thereby affected.
12. Cabinetry will be delivered direct to job site. All protection of job site floors and walls ... responsible for damages to unprotected surfaces. If job site is not able to receive cabinetry, Purchaser will be subject to storage
and redelivery charges to be specified by Change Order ... date but must be stored a total of 90% of purchase price for the
cabinetry as set forth in this Agreement, will become due prior to storage with the final
https://www.justice.gov/epstein/files/DataSet%209/EFTA00555767.pdf