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e Virgin Islands is an improper venue.'9 It is Fancelli's burden to prove that the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, is an improper venue.50 Under Virgin Islands law, courts (Def. is Mot. to Dismiss 13.) FED. R. CTV. P. I 9(aX I). RESTATEMENT (SECOND) OF CONTRAC
.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little St. James. Molyneux has offices in New York, New York
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
nd 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 incorporated and maintains its principal place of business in the State of New York (-Studio"). 3. In 2005, Jeffrey Epstein ("Epstein")
ell as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle all Disputes and the Lawsuit as provide
lli of certain cabinetry on Little St. James Island in the United States Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-44
sputes"); and WHEREAS, the Parties are parties to a lawsuit now pending before the District Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. 3:10-cv-00034 (the "Lawsuit"); and WHEREAS, the parties hereto desire to settle all Disputes and the Lawsuit as provided in this A
THIS SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is entered into as of this day of November, 2010, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have arisen between Molyneux a
ell as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle all Disputes and the Lawsuit as provide
lli of certain cabinetry on Little St. James Island in the United States Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-44
sputes"); and WHEREAS, the Parties are parties to a lawsuit now pending before the District Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. 3:10-cv-00034 (the "Lawsuit"); and WHEREAS, the parties hereto desire to settle all Disputes and the Lawsuit as provided in this A
THIS SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is entered into as of this day of November, 2010, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have arisen between Molyneux a
Entities connected to both St. John and J.P. Molyneux Studio, Ltd.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSONV.I.C.
ORGANIZATION
New York
LOCATIONthe Superior Court of the Virgin Islands
ORGANIZATIONL.S.J.
ORGANIZATIONFancelli
PERSONthe State of New York
LOCATIONDivision of St. Thomas
ORGANIZATION
V.I.
LOCATION
New York City
LOCATIONJean Pierre Fancelli
PERSONJuan Pablo Molyneux
PERSONStudio
PERSONJay Goldberg
PERSON
Russell Simmons
PERSONDenise Francois
PERSONThe Epstein Releasors
ORGANIZATION