EFTA00309181Set 9
2010-11-2959p17,228w
DEFENDANT'S MOTION TO DISMISS
CD
The motion to dismiss filed by Defendant Fancelli Paneling, Inc. ("Defendant") in the
above-captioned action misstates New York law, improperly relies upon allegations ... foregoing, service of the summons and the FAC was validly effected
upon Defendant Fancelli Paneling, Inc. and Defendant's motion to dismiss based upon
ineffective service of process must ... Case No. ST-10-CV-443
II. THIS COURT HAS PERSONAL JURISDICTION OVER DEFENDANT
FANCELLI PANELING, INC.
A. Legal Standard for Evaluating a Motion to Dismiss for Lack of Personal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00309181.pdf
EFTA01112521Set 9
2012-07-135p1,090w
obtain a
date on which all parties and the mediator were available, Defendant Fancelli Paneling, Inc.'s
counsel sent the following email ... During the course of rescheduling the mediation, legal counsel for the Defendant
Fancelli Paneling sent the following email to the American Mediation Institute and other parties:
2
EFTA01112522
Plaintiffs' Emergency ... fabrication of the interior of a library calls into question
whether the Defendant Fancelli Paneling, Inc. intends to mediate in good faith.
6. By the foregoing June 1, 2012 email
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112521.pdf
EFTA00310004Set 9
2010-08-1026p8,275w
OPPOSITION TO MOTION TO DISMISS THE COMPLAINT
WITH POINTS AND AUTHORITIES
COMES NOW Defendant, FANCELLI PANELING, INC. ("Fancelli"), by and
through its undersigned counsel, to provide its Reply to Plaintiffs
https://www.justice.gov/epstein/files/DataSet%209/EFTA00310004.pdf
EFTA01098959Set 9
2012-08-1017p6,168w
Superior Court Rule 7, hereby moves to dismiss the Cross-Claim: of defendant Fancelli Paneling,
Inc. ('Fancelli"), for failure to state claims on which relief can b.: granted, as there
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098959.pdf
EFTA01120429Set 9
2011-05-2437p2,724w
March 14, 2012, as and for their Second
Amended Complaint against the Defendants, Fancelli Paneling, Inc. and J. P. Molyneux
Studio, Ltd., state the following:
1. The Plaintiff, Jeffrey Epstein ... Upon information and belief, at all times relevant herein, Defendant Fancelli
Paneling, Inc. ("Fancelli") was a corporation, incorporated in the State of New York engaged
in the business of restoration ... arising from the subject matter of this action (expressly
preserving their claims against Defendant Fancelli Paneling, Inc.) and do not allege any
claims or causes of action herein against
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120429.pdf
EFTA00309172Set 9
2011-05-249p2,164w
CARROLL III...
ORDER SIGNED BY HON. JAMES S. CARROLL III..
ORDERED THAT DEFENDANT FANCELLI PANELING, INC.'S JANUARY 13, 2011
MOTION TO DISMISS IS DENIED; AND IT IS FURTHER ... EPSTEIN AND ...
05/16/2011 ORDER SIGNED BY HON. JAMES S. CARROLL III...
ORDERED TAHT DEFENDANT FANCELLI PANELING. INC.'S MARCH 14, 2011
MOTION TO FILE OUT OF TIME AND FOR ACCEPTANCE ... DEFENDANT'S REPLY TO OPPOSITION IS GRANTED; AND IT IS FURTHER
ORDERED THAT DEFENDANT FANCELLI PANELING. INC'S MARCH 15, 2011
MOTION FOR LEAVE TO FILE AN AMENDED REPLY
https://www.justice.gov/epstein/files/DataSet%209/EFTA00309172.pdf
EFTA01099088Set 9
2010-08-1021p5,745w
REPLY TO OPPOSITION TO MOTION TO DISMISS
WITH POINTS AND AUTHORITIES
COMES NOW Defendant, FANCELLI PANELING, INC. ("Fanelli"), by and
through its undersigned counsel, to provide its Reply to Plaintiffs
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099088.pdf
EFTA01114241Set 9
9p2,549w
Plaintiffs, )
)
v. ) NO. ST-10-CV-443
)
FANCELLI PANELING, INC., )
) (CARROLL, J.)
Defendant. )
)
DEFENDANT FANCELLI PANELING, INC.'S
OPPOSITION TO MOTION TO DISMISS CROSS-CLAIMS AND
MOTION TO DISMISS ... SECOND AMENDED COMPLAINT
WITH POINTS & AUTHORITIES
COMES NOW Defendant, FANCELLI PANELING, INC. ("Fancelli"), by and through
its undersigned Counsel, to submit its Opposition to Defendant, J.P. MOLYNEUX STUDIO
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114241.pdf
EFTA00307083Set 9
2011-05-2413p5,972w
Plaintiffs Counsel for Defendant
CARROLL, Judge
I MEMORANDUM OPINION
(Filed: May /S. , 2011)
Defendant Fancelli Paneling, Inc., ("Fanelli") moves to dismiss Plaintiffs' First
Amended Complaint, arguing, among other things, that ... reasons stated in the Memorandum Opinion issued today, it is hereby
ORDERED that Defendant Fancelli Paneling, Inc.'s January 13, 2011 Motion to Dismiss
is DENIED; and it is further
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307083.pdf
EFTA01147271Set 9
2012-07-026p1,151w
review 0 Please I: Please reply U Please recycle
Opposition of Defendant Fancelli Paneling, Inc. to Plaintiffs' Emergency Motion
to Compel the Attendance of (Monsieur) Jean-Pierre Fancelli follows this ... FANCELLT PANELING, INC., and
S.F. MOLYNEUX STUDIO, LTD.,
(CARROLL, J.)
Defendants.
OPPOSITION OF DEFENDANT FANCELLI PANELING, INC., TO PLAINTIF
FS'
EMERGENCY MOTION TO COMPEL THE ATTENDANCE OF (MONSIEUR)
JEAN-PIERRE ... P.005
07/05/2012 16:16 3407775498 MOORE DODSON RUSSELL PAGE 04/05
OPPOSITION OF DEFENDANT FANCELLI PANELING. INC.
TO PLAINTIFFS' EMERGENCY MOTION TO COMPEL PANCELLPS
Epstein, et al. P. Pance/li Paneling
https://www.justice.gov/epstein/files/DataSet%209/EFTA01147271.pdf
EFTA00731209Set 9
8p1,893w
their undersigned counsel, Hodge & Francois, and as and
for their complaint against the Defendant, Fancelli Paneling, Inc., state the following:
1. The Plaintiff, Jeffrey Epstein ("Epstein"), is a resident
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731209.pdf
FANCELLI PANELING, INC., )
) (CARROLL, J.)
Di Pendant. )
)
DEFENDANT FANCELLI PANELING, INC.'S
MOTION TO ENTER UPON LAND FOR INSPECTION AND OTHER PURPOSES
WITH POINTS & AUTHORITIES
COMES NOW Defendant, FANCELLI PANELING
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112363.pdf
EFTA01099083Set 9
2006-06-155p950w
PANELING, INC., )
) (CARROLL, J.)
Defendant. )
)
DEFENDANT'S RULE 26(a) DISCLOSURES
COMES NOW DEFENDANT, FANCELLI PANELING, INC., by and through its
undersigned counsel, to provide herewith its initial discovery disclosures
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099083.pdf
EFTA01145884Set 9
2012-12-304p871w
arrange a face-to-face meeting in Paris, France, with the principal of
Defendant Fancelli Paneling, Inc., Mr. Jean Pierre Fancelli, to resolve this case. By email dated
October ... through December 30, 2012 is not unreasonable. Moreover, the attached
emails demonstrate that Defendant Fancelli Paneling, Inc. also desires to continue face-to-face
2
EFTA01145885
Plaintiffs' Motionfor Enlargement ... quoting Wright & Miller 4B Fed. Prac. & Proc. Civ. &1165 (3d. ed.). Plaintiffs' and Defendant
Fancelli Paneling, Inc.'s mutual desire to continue settlement negotiations clearly demonstrates
the absence of both
https://www.justice.gov/epstein/files/DataSet%209/EFTA01145884.pdf
EFTA00308339Set 9
2010-03-119p2,616w
extraordinary violation of LRCi 7.1 governing motion practice before this Coy,
the Defendant Fancelli Paneling, Inc. ("Defendant") filed on March 11, 2010 Defendant's
Amended Reply to Opposition to Motion ... Court disapproved the Stipulation to which the
parties had agreed and ordered that "Defendant Fancelli Panelling, Inc. must FILE its Motion to
File its Reply Out of Time
https://www.justice.gov/epstein/files/DataSet%209/EFTA00308339.pdf
EFTA01114400Set 9
2011-03-072p839w
Opposition to the Motion to
Dismiss.
Accordingly, it is hereby
ORDERED that Defendant Fancelli Paneling, Inc.'s March 14, 2011 Motion to File Out
of Time and For Acceptance Nunc ... Defendant's Reply to Opposition is GRANTED:
and it is further
ORDERED that Defendant Fancelli Paneling, Inc.'s March 15, 2011 Motion for Leave
to File an Amended Reply ... DENIED; and it is further
ORDERED that Defendant Fancelli Paneling, Inc.'s March 11, 2011 Amended Reply is
REJECTED; and it is further
ORDERED that copies of this Order shall
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114400.pdf
EFTA00602420Set 9
2012-07-197p1,278w
FRANCOIS MOORE DODSON & RUSSELL, P.C.
Counsel for Plaintiff Epstein, et al. Counsel for Defendant Fancelli Paneling, Inc.
1340 Taameberg P.O. Box 310, E.G.S. (I4A Norre Gade)
St. Thomas
https://www.justice.gov/epstein/files/DataSet%209/EFTA00602420.pdf
EFTA01098979Set 9
2011-03-105p722w
LEAVE TO FILE AN AMENDED REPLY
WITH POINTS AND AUTHORITIES
COMES NOW Defendant, FANCELLI PANELING, INC. ("Fanelli"), by and through
its undersigned counsel, to move this Honorable Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098979.pdf
EFTA00300053Set 9
2011-06-0711p2,708w
cabinetry is a Purchase Order #2680 dated June 15, 2006,
between "MOLYNEUX" and Defendant, Fancelli Paneling, as replaced by Purchase Order
#7106 dated October 14, 2008, the full scope
https://www.justice.gov/epstein/files/DataSet%209/EFTA00300053.pdf