IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- FANCELLI PANELING, INC., Defendant, -vs- J.P. MOLYNEUX STUDIO, LTD., Nominal Defendant. CASE NO. ST-10-CV-443 ACTION FOR DAMAGES JURY TRIAL DEMANDED PLAINTIFFS' EMERGENCY MOTION TO 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) move this Court, pursuant to Super. Ct. Rule 40(e) and 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 matter for July 13, 2012. As grounds for this Motion the Plaintiffs rely upon the following: 1. Mr. Jean-Pierre Fancelli is the president of Fancelli Paneling, Inc ("Fancelli"). The Library Cabinetry which is the subject of the above-captioned action was fabricated by and/or the supervision of Mr. Fancelli. In fact, its Rule 26(a) Disclosures, Fancelli Paneling, Inc. it states: Mr. Jean Pierre, the principal of Fancelli Paneling, Inc., 24 East 6e Street, New York, New York, 10021, has knowledge of all aspects of the transactions and work he provided forming the bases for some of the claims and defenses herein, including EFTA01112521