Trenton E. Moore

Trenton E. Moore J. Daryl Dodson Charles S. Russell. Jr. Jessica Chung Michele Baker MOORS DODSON & RUSSELL,Ill. ATTORNEYS AT LAW 5035 (I4A) None Gads, Suite I Post Office Box 310, St. Thomas, VI. 00804-0310 Telephone Facsimile ( March 14, 2011 VIA HAND DELIVERY Honorable James Carroll Superior Court of the Virgin Islands Alexander A. Farrelly Justice Center Veterans Drive St. Thomas, V.I. 00802 . . . . . . . . . . . . . . nuc e eamdrvi.com RE: SPSTEDV, et al v. FANCELLI PANELING Dear Judge Carroll: Due to a variety of unanticipated events, I ran out of time on Thursday, March 10, 2011, to submit the several things due in this and other matters that date. In this matter, I submitted an incomplete Reply to Plaintiffs' Opposition to Motion to Dismiss and a brief Motion to Extend the time in which I was to "show cause" for the additional time needed to do so on March 101h. I filed an Amended Reply that correctly reflected everything this Client wanted in its Reply the following day after a full day of organizing everything required to do so. My Client is not comfortable communicating in English. His long-time Counsel in New York has a preferred way of doing things as a consequence of this and habit and I am just adjusting time and protocols to account for coordinating matters that way on this end. Enclosed, please find the (proposed) Order extending the time in which to provide the reasons to extend. ENCLOSURE cc w/Encl.: Denise Francois, Esq. EFTA01110952 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN, et al., * * * * * ) ) ) Plaintiffs, ) ) v. ) NO. ST-10-CV-443 ) FANCELLI PANELING, INC., ) ) Defendant. ) (CARROLL, J.) ) ORDER THIS MATTER comes on the Defendant's March 10, 2011 Motion to Extend Time in Which to Respond to the Court's Order to Show Cause; and it APPEARING TO THE COURT that said Motion should be granted for good cause shown, it is hereby ORDERED that the Defendant shall have until , 2011, in which to file its response(s); and it is further ORDERED ENTERED THIS DAY OF 2011: EFTA01110953 ORDER ,Enstein. et al. v. Fancelli Page 2 Hon. JAMES CARROLL, JUDGE SUPERIOR COURT OF THE V I. ATTEST: Venetia H. Velazquez, Esq. CLERK OF COURT By: (Deputy) clerk Distribution list: All Counsel of Record EFTA01110954