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over a purchase order. The dispute is over Library Cabinetry that is located on Little St. James island in the Judicial District of St. Thomas and St. John. Defendant delivered a product to the Virgin Islands that it incompletely and improperly installed in defective condition in the Virgin Islands. Th
aintiffs FAC and the exhibits attached thereto. 2. Plaintiffs Have Filed Their Lawsuit in the Proper Venue: The St. Thomas and St. John Division of the Superior Court. Defendant also suggests that this case be dismissed because the venue is improper. "To survive a motion to dismiss for improper venue, the plainti
4 (Protocol); see Ex. A ¶ 16 Decl.). 2G Ex. D at 4 (Protocol). 21 See https://vvww.epsteinvcp.comf; see also Ex. D at 1-2 (Protocol). Thomas and St. John, Crim. P. 17(c)(3), EFTA00078649 November 19, 2021 Page Five Estate."22 The program is also "purely voluntary"; claimants' rights are not impac
arial, [and] confidential" basis.2' For example, the EVCP operates "entirely free from any interference or control by the Epstein " Ex. G (order of the Superior Court of t1 lit• in Islands Division of St. ( Virgin dated June 2, 2020); see Ex. A ¶¶ 8, 13 Decl.). " Ex. C (6/25/20 Press Release). 16 Maxwell's Mo
n the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of the United States Virgin Islands under Chapter 30 of the V
iminal Activity Lien Notice pursuant to Chapter 30, Title 14 § 610, in the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of
Entities connected to both St. John and the Superior Court

Jeffrey Epstein
PERSON
Richard Kahn
PERSONDaphne Wallace
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON
Sarah Ferguson
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Charles
PERSONV.I.C.
ORGANIZATIONMaria Farmer
PERSONLeon Black
PERSON
Oliver Stone
PERSON
New York
LOCATIONU.S. Virgin
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSONthe Superior Court of the Virgin Islands
ORGANIZATION