Epstein Secrets

stalled. Plaintiffs' forum choice is their home forum. Defendant has not met its heavy burden in opposing Plaintiffs' chosen forum. Sinochem Intern. Malaysia Intern. Shipping, 549 U.S. 421 at 430 (2007). Defendant's forum non conveniens argument is based upon the false premise that Plaintiffs are residen

n. Shipping, 549 U.S. 421 at 430 (2007). Defendant's forum non conveniens argument is based upon the false premise that Plaintiffs are residents of the State of New York when the FAC specifically alleges that Plaintiff Jeffrey Epstein is a resident of the Virgin Islands and that L.S.I., LLC maintains its principal a

EW YORK ) ss: COUNTY OF New YAK AFFIDAVIT OF JUAN PABLO MOLYNEUX JUAN PABLO MOLYNEUX, after being duly sworn, deposes and says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorpora

federal court. Argen- tine Republic v. Amerada Hess Shipping Corp., 488 U.S. 428, 439, 109 S.CL 683, 102 L.Ed.2d 818 (1989); Robinson v. Gov't of Malaysia, 269 F.3d 133, 138 (2d Cir.2001). Federal courts must inquire at the "threshold of every action" against a for- eign state whether the exercise of

where the complaint stated, without any supporting facts, that the defendant "participates in a 'multina- tional insurance arrangement' present in the State of New York"); In re Ski Train Fire in Kaprun, Austria, 230 F.Supp.2d at 410-413 (granting motion to dismiss and denying jurisdictional discovery where compl

cy of companies which are neither incorporated in Singapore nor tax resident in Singapore. excluding stocks and shares of companies incorporated in Malaysia which are listed on the Singapore Exchange or on the Kuala Lumpur Stock Exchange; (b) securities (other than stocks and shares) denominated in any f

ership's Independent Public Accountants: ML281817-MAXWELL In 2005, Millennium entered into a settlement with the SEC and the Attorney General of the State of New York pursuant to which the Millennium parties to the settlement neither admitted nor denied any wrongdoing but agreed to make certain payments as disgo

cy of companies which are neither incorporated in Singapore nor tax resident in Singapore. excluding stocks and shares of companies incorporated in Malaysia which are listed on the Singapore Exchange or on the Kuala Lumpur Stock Exchange; (b) securities (other than stocks and shares) denominated in any f

Partnership's Independent Public Accountants: MM -MAXWELL In 2005, Millennium entered into a settlement with the SEC and the Attorney General of the State of New York pursuant to which the Millennium parties to the settlement neither admitted nor denied any wrongdoing but agreed to make certain payments as disgo