EFTA01120429Set 9
2011-05-2437p2,724w
well as the delivery and
installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry")
for the library in the Office Pavilion. Molyneux's design for the library ... 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 ... hereto. Molyneux also presented Epstein with Molyneux's own
rendering of the proposed Library Cabinetry. A copy of Molyneux's rendering is attached as
Exhibit "2" hereto. On the basis
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120429.pdf
EFTA00731209Set 9
8p1,893w
well as the delivery and
installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry")
for the library in the Office Pavilion. Molyneux's design for the library ... 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 ... hereto. Molyneux also presented Epstein with
Molyneux's own rendering of the proposed Library Cabinetry. A copy of Molyneux's
2
EFTA00731210
rendering is attached as Exhibit "2" hereto
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731209.pdf
EFTA00589459Set 9
8p2,166w
wood paneling and sliding
window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design
for the library of the Office Pavilion, as agreed ... 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 ... Spain. I
also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the
basis of both photographs of the library at El Escorial, and my drawing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589459.pdf
EFTA02407959Set 11
9p2,188w
wood paneling and sliding
window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for
the library of the Office Pavilion, as agreed ... 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 ... Spain. I
also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the
basis of both photographs of the library at El Escorial, and my drawing
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02407959.pdf
EFTA00722277Set 9
8p2,167w
wood paneling and sliding
window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design
for the library of the Office Pavilion, as agreed ... 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 ... Spain. I
also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the
basis of both photographs of the library at El Escorial, and my drawing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722277.pdf
EFTA01071594Set 9
7p1,885w
wood paneling and sliding
window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design
concept for the library of the Office Pavilion, as agreed ... 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 ... Epstein approved the general design, color and finish of the proposed Library
Cabinetry. Mr. Epstein and I later agreed to certain modifications to that design which
required that the columns
https://www.justice.gov/epstein/files/DataSet%209/EFTA01071594.pdf
EFTA00725567Set 9
2010-09-165p1,243w
well as the delivery and
installation of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry") for
the library in the Office Pavilion. Molyneux's design for the library ... 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 ... Molyneur Studio, Ltd. vs. Epstein et al.
Civil No. 2010/34
rendering of the proposed Library Cabinetry. Molyneux's $780,000 proposal for the Library
Cabinetry, accepted by Epstein, specifically calls
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725567.pdf
EFTA01099088Set 9
2010-08-1021p5,745w
Plaintiffs 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 ... Plaintiffs' designated agent, Gary Kerney, Plaintiffs approve the fabrication,
installation and finishing of the Library Cabinetry, as follows:
The work executed by Fancelli Paneling following the project designed by
Molyneux ... together with
plaintiff e-mail dated March 17, 2010, directing that communication regarding the
Library Cabinetry is to be with Gary Kearney, himself or his counsel. Def.
Exhibit
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099088.pdf
EFTA00307562Set 9
2011-05-2411p3,281w
cabinetry,
bookshelves, columns, and wood paneling for the library of the Office Pavilion (the "Library
Cabinetry"). Under third party beneficiary status, Plaintiffs filed suit against Fancelli for breach
EFTA00307562
MEMORANDUM ... Super. Cs Case No. ST-10-CV-443
of contract and negligence because the Library Cabinetry is defective and installation was
incomplete. Plaintiffs and Molyneux entered into a confidential settlement ... litigation. Plaintiffs succeeded in settling their claims against
Molyneux, including those relating to the Library Cabinetry, but were unable to do so with
Fancelli and, as a result, filed suit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307562.pdf
EFTA00307578Set 9
2011-05-2417p4,736w
Motionfor Reconsideration
Epstein et at vs. Fancelli Paneling, Inc.
Case No. ST-I0-CV443
"Library Cabinetry"). As third party beneficiaries of that contract with Fancelli, Plaintiffs filed
suit against Fancelli ... 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 ... litigation. Plaintiffs succeeded in settling their claims against
Molyneux, including those relating to the Library Cabinetry, but were unable to do so with
Fancelli and, as a result, filed suit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307578.pdf
EFTA00728042Set 9
2010-04-145p2,098w
important 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 ... Island.
The cabinetry was to be an exact duplicate of the cabinetry in the library of El
Escorial in Spain. In order to ensure that it was reproduced in exacting ... subcontractors to the site to refinish the cabinetry, but could not
do so because the ambient humidity levels in the library and moisture content of the
furniture exceeded certain requirements
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728042.pdf
EFTA00731251Set 9
7p3,082w
continuously engaged in pattern of deceit and other misconduct,
particularly in relation to the library cabinets for the office pavilion. As the
extensive email traffic between Mr. Epstein ... 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.
More than ... cabinetry needed to be dark
stained walnut consistent with the original cabinetry in the El Escorial library and as
originally rendered by Mr. Molyneux. In fact, the original purchase order
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731251.pdf
EFTA00728406Set 9
2010-04-155p1,774w
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
EFTA00722178Set 9
2010-10-143p998w
Fancelli's
questions and issues relating to required completion work for library cabinetry.
Now, three weeks later, Mr. Fancelli and his people are still not on the Island and
have ... window shutters in the library (estimated by Fancelli at
47,992 Euros), as well as the costs to stain the cabinetry. However, you have not
confirmed your client's agreement ... created a complete video record to
demonstrate all of the shoddy work on the library cabinetry should it be necessary
to proceed with litigation. The choice is Mr. Molyneux
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722178.pdf
EFTA00722175Set 9
2010-10-143p991w
Fancelli's
questions and issues relating to required completion work for library cabinetry.
Now, three weeks later, Mr. Fancelli and his people are still not on the Island and
have ... window shutters in the library (estimated by Fancelli at
47,992 Euros), as well as the costs to stain the cabinetry. However, you have not
confirmed your client's agreement ... created a complete video record to
demonstrate all of the shoddy work on the library cabinetry should it be necessary
to proceed with litigation. The choice is Mr. Molyneux
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722175.pdf
EFTA01085328Set 9
2012-04-0422p4,448w
with
Molyneux," but denies the allegation for hose benefit Defendant fabricated and
installed the library cabinetry and refers the website for the representations
therein.
8. Defendant only admits so much ... allegations container ii 1110.G
including, but not limited to,
the allegation that the cabinetry was "no , properly sealed,"
is currently without
information sufficient to admit, or deny allegations relating ... allegations contained 110.H, including, but not limited to,
the allegation that the Library Cabinetry as niggled was contrary
to the Purchase
Orders with Molyneux, and refers
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085328.pdf