EFTA01098959Set 9
2012-08-1017p6,168w
L.S.J., LLC,
CIVIL NO. 2010/443
Plaintiffs,
AC ION FOR DAMAGES
v.
JURY TRIAL DEMANDED
FANCELLI PANELING, INC., and
J.P. MOLYNEUX STUDIO, LTD.,
Defendants.
)
MOTION TO DISMISS CROSS-CLAIMS
OF FANCELLI ... 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 ... legal or
factual basis on which Fancelli could be awarded indemnification or contribution from JPMS, and
as Fancelli has failed to plead facts which, if proven, would ends
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098959.pdf
EFTA00309181Set 9
2010-11-2959p17,228w
CASE NO. ST-10-CV-443
) C •
vs- ) ACTION FOR DAMAGES
) C;
C I
FANCELLI PANELING, INC., ) JURY TRIAL DEMANDED
)
Defendant. )
ci
PLAINTIFFS' OPPOSITION TO DEFENDANT'S MOTION TO DISMISS ... motion to dismiss filed by Defendant Fancelli Paneling, Inc. ("Defendant") in the
above-captioned action misstates New York law, improperly relies upon allegations not
contained in Plaintiffs' first amended complaint ... issue in this case.
The Affidavit of Process Server confirms, under oath, that Fancelli Paneling, Inc. was
served with the summons and the FAC at its business address located
https://www.justice.gov/epstein/files/DataSet%209/EFTA00309181.pdf
EFTA00307083Set 9
2011-05-2413p5,972w
JOHN
EFFREY EPSTEIN
CASE NO. ST-10-CV-0000443
ACTION FOR: DAMAGES - CIVIL
vs
FANCELLI PANELING, INC.,
Defendant
NOTICE OF ENTRY OF
MEMORANDUM OPINION
AND ORDER
TO: DENISE FRANCOIS ... L.S.J., LLC., ) CIVIL NO. ST-I0-CV-443
)
Plaintiffs, )
)
v. ) ACTION FOR DAMAGES
)
FANCELLI PANELING, INC., )
) JURY TRIAL DEMANDED
Defendant. )
DENISE FRANCOIS, ESQ. TRESTON MOORE, ESQ.
Hodge & Francois Moore Dodson ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307083.pdf
EFTA01114241Set 9
9p2,549w
THOMAS & ST. JOHN
* * * * *
)
JEFFREY EPSTEIN, et al., )
)
Plaintiffs, )
)
v. ) NO. ST-10-CV-443
)
FANCELLI PANELING, INC., )
) (CARROLL, J.)
Defendant. )
)
DEFENDANT FANCELLI PANELING, INC.'S
OPPOSITION TO MOTION TO DISMISS ... MOTION TO DISMISS THE 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 ... James Island, U.S. Virgin Islands. As part of the design, Molyneux contracted with Fancelli to
fabricate certain cabinetry that would be installed in a building known as the "Office Pavilion
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114241.pdf
EFTA00589459Set 9
8p2,166w
Epstein and I later
EFTA00589459
Affidavit of Juan Pablo Molyneux
Epstein et al. vs. Fancelli Panelling, Inc.
agreed to certain refinements to that design which required that the columns ... relating to the Office
Pavilion, Epstein and I agreed that Studio would contract with Fancelli Paneling, Inc., a New
York corporation ("Fancelli"), to fabricate, stain, finish, deliver and install ... Library
Cabinetry for the benefit of Epstein and LSJ. Fancelli holds itself out as skilled in intricate
wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589459.pdf
EFTA00722277Set 9
8p2,167w
Epstein and I later
EFTA00722277
Affidavit of Juan Pablo Molyneux
Epstein et al. vs. Fancelli Panelling, Inc.
agreed to certain refinements to that design which required that the columns ... relating to the Office
Pavilion, Epstein and I agreed that Studio would contract with Fancelli Paneling, Inc., a New
York corporation ("Fancelli"), to fabricate, stain, finish, deliver and install ... Library
Cabinetry for the benefit of Epstein and LSJ. Fancelli holds itself out as skilled in intricate
wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722277.pdf
EFTA00731209Set 9
8p1,893w
EPSTEIN and L.S.J., LLC, )
)
Plaintiffs, ) CASE NO. ST-10-CV-
)
-vs- ) ACTION FOR DAMAGES
)
FANCELLI PANELING, INC., ) JURY TRIAL DEMANDED
and ATELIER FANCELLI, I
)
Defendants. )
COMPLAINT
COME NOW, the Plaintiffs ... 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 ... principal address in the United States
Virgin Islands.
I 3. Upon information and belief, Fancelli Paneling Inc. ("Fancelli") is a
corporation, incorporated in the State of New York, which
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731209.pdf
EFTA01120429Set 9
2011-05-2437p2,724w
L.S.J., LLC,
Plaintiffs, CASE NO. ST-10-CV-443
-vs- ACTION FOR DAMAGES
FANCELLI PANELING, INC., JURY TRIAL DEMANDED
Defendant,
-vs-
J.P. MOLYNEUX STUDIO, LTD.,
Nominal Defendant.
SECOND AMENDED COMPLAINT ... 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 ... United States Virgin Islands.
EFTA01120429
Second Amended Complaint
Epstein et al. vs. Fancelli Panelling, Inc
Case No. ST-10-CV-443
3. Upon information and belief, at all times relevant
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120429.pdf
EFTA02407959Set 11
9p2,188w
later
EFTA_R1_01467544
EFTA02407959
Affidavit of Juan Pablo Molyneux
Epstein et al. vs. Fancelli Panelling, Inc.
agreed to certain refinements to that design which required that the columns ... relating to the Office
Pavilion, Epstein and I agreed that Studio would contract with Fancelli Paneling, Inc., a New
York corporation ("Fancelli"), to fabricate, stain, finish, deliver and install ... Library
Cabinetry for the benefit of Epstein and LSJ. Fancelli holds itself out as skilled in intricate
wood sculpting and specializing in the reproduction of fine antique cabinetry and woodwork
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02407959.pdf
EFTA01071594Set 9
7p1,885w
design be intricately carved
EFTA01071594
Affidavit of Juan Pablo Molyneux
Epstein et al. vs. Fancelli Panelling, Inc.
with representations of marine flora and fauna consistent with a tropical locale. Additional ... relating to the Office
Pavilion, Epstein and I agreed that Studio would contract with Fancelli Paneling, Inc., a New
York corporation ("Fancelli"), to fabricate, finish, deliver and install the Library ... Cabinetry for
the benefit of Epstein and LSJ. Fancelli holds itself out as skilled in intricate wood sculpting
and specializing in the reproduction of fine antique cabinetry and woodwork. Fancelli
https://www.justice.gov/epstein/files/DataSet%209/EFTA01071594.pdf
EFTA00307578Set 9
2011-05-2417p4,736w
Plaintiffs, CASE NO. ST-10-CV-443 -:j
• z
-vs- ACTION FOR DAMAGES
FANCELLI PANELING, INC., JURY TRIAL DEMANDED cr1
0
0
Defendant.
MEMORANDUM IN SUPPORT OF PLAINTIFFS' MOTION ... Saint James Island
known as the Office Pavilion (the "Office Pavilion"). Molyneux contracted with Fancelli
Paneling, Inc. ("Fancelli" or "Defendant"), a New York corporation, to custom make the
cabinetry, bookshelves ... Office Pavilion (the
EFTA00307578
Memorandum in Support ofPlaintiffs' Motionfor Reconsideration
Epstein et at vs. Fancelli Paneling, Inc.
Case No. ST-I0-CV443
"Library Cabinetry"). As third party beneficiaries of that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307578.pdf
EFTA01099088Set 9
2010-08-1021p5,745w
THOMAS & ST. JOHN
..................
)
JEFFREY EPSTEIN, et at, )
)
Plaintiffs, )
)
v. ) NO. ST-10-CV-443
)
FANCELLI PANELING, INC., )
)
Defendant. ) (CARROLL, J.)
)
DEFENDANT'S AMENDED 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' Opposition to Motion to
Dismiss the First ... DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS
,Epstein. et at v. Fancelli Paneling. Inc.
Page 4
I. THE SUMMONS AND FIRST AMENDED COMPLAINT WERE NOT PROPERLY
SERVED
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099088.pdf
EFTA01112521Set 9
2012-07-135p1,090w
L.S.J., LLC,
Plaintiffs, CASE NO. ST-10-CV-443
-vs- ACTION FOR DAMAGES
FANCELLI PANELING, INC., JURY TRIAL DEMANDED
Defendant,
-vs-
J.P. MOLYNEUX STUDIO, LTD.,
Nominal Defendant.
PLAINTIFFS' EMERGENCY MOTION ... COMPEL THE ATTENDANCE OF MR.
JEAN-PIERRE FANCELLI AT MEDIATION
The Plaintiffs Jeffrey Epstein and L.S.J., LLC ("Plaintiffs"), by and through their
undersigned counsel, Hodge & Francois (Denise Francois, of counsel ... this Court's inherent authority, for entry of an order directing Mr.
Jean Pierre Fancelli, the President of Fancelli Paneling, Inc. to appear at the mediation presently
scheduled in this
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112521.pdf
EFTA01077826Set 9
2009-10-1612p2,620w
Fancelli Paneling
Additional cost incurred
Amount
Gary Kerney Cost - 12 months $ 358,745
Tom Melnick - 12 months $ 128,640
Bill Adams - 12 months $ 95,856
Fancelli - October 2009 additional installation ... Island Ground labor - project delays
$ 29,213 $ 29,213
Fancelli additional costs $ 705,060
Fancelli legal fees $ 66,297
Molyneux legal fees $ 59,891
Total additional costs $ 831,248
EFTA01077826 ... from the above account to:
Bank:
IBAN:
Swift:
4 zg
Account Name:
Reference: Fancelli
Please email Rich Kahn with the Fed Reference number.
0[6,
JAI
&ids'
EFTA01077829
Rich Kahn
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077826.pdf
EFTA00655538Set 9
2013-12-3113p2,733w
into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli
Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"),
L.S.J ... Jeffrey Epstein ("JE", and together with LSJ, "Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... accordance with the provisions of this Agreement
1
EFTA00655538
2. At Fancelli's sole risk, cost and expense, and at no charge or cost to
Epstein, Fancelli shall design, provide
https://www.justice.gov/epstein/files/DataSet%209/EFTA00655538.pdf
EFTA00585825Set 9
2013-12-3113p2,737w
into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli
Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"),
L.S.J ... Jeffrey Epstein ("JE", and together with LSJ, "Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... upon, subject
to and in accordance with the provisions of this Agreement
2. At Fancelli's sole risk, cost and expense, and at no charge or cost to
Epstein, Fancelli
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585825.pdf
EFTA01121143Set 9
2013-12-3113p2,735w
into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli
Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"),
L.S.J ... Jeffrey Epstein ("JE", and together with LSJ, "Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... upon, subject
to and in accordance with the provisions of this Agreement
2. At Fancelli's sole risk, cost and expense, and at no charge or cost to
Epstein, Fancelli
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121143.pdf
EFTA00584723Set 9
2013-12-3113p2,737w
into as of this day of June, 2013 (the "Effective Date"), by and among Fancelli
Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI, "Fancelli"),
L.S.J ... Jeffrey Epstein ("JE", and together with LSJ, "Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... upon, subject
to and in accordance with the provisions of this Agreement
2. At Fancelli's sole risk, cost and expense, and at no charge or cost to
Epstein, Fancelli
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584723.pdf
EFTA01082128Set 9
11p2,338w
entered
into as of this day of 2013 (the "Effective Date"), by and among
Fancelli Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI,
"Fancelli"), L.S.J ... Jeffrey Epstein ("JE", and together with LSJ,
"Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... before the (_th) day after the Effective Date (the
"Completion Date"), Fancelli, at Fancelli's sole risk and expense, shall design, build,
finish, ship to Epstein at his address
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082128.pdf
EFTA01082141Set 9
11p2,345w
entered
into as of this day of 2013 (the "Effective Date"), by and among
Fancelli Paneling, Inc. ("FPI"), Jean Pierre Fancelli ("JPF", and together with FPI,
"Fancelli"), L.S.J ... Jeffrey Epstein ("JE", and together with LSJ,
"Epstein").
WHEREAS, disputes have arisen between Fancelli and Epstein relating to,
among other things, the fabrication, finish and installation by Fancelli of certain ... before the (_d1) day after the Effective Date (the
"Completion Date"), Fancelli, at Fancelli's sole risk and expense, shall design, build,
finish, ship to Epstein at his address
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082141.pdf