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AVIT OF GARY KERNEY I. GARY KERNEY, after being duly sworn, depose and say: I. That I am an independent contractor hired to manage construction on Little St. James Island. 2. In my capacity as a construction manager I have routine access to and have personally reviewed the log books kept in the regular
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
member of L.S.J., LLC. 2. The Plaintiff, L.S.J., LLC ("LSJ"), is a limited liability company organized under the laws of Delaware, is the owner of Little St. James Island located off the coast of St. Thomas, United States Virgin Islands and maintains its principal address in the United States Virgin Isla
ddress in the United States Virgin Islands. 3. Upon information and belief, Fancelli Paneling Inc. ("Fancelli") is a corporation, incorporated in the State of New York, which is engaged in the business of restoration and reproduction of antique wood panels and cabinetry in the United States, Canada and Europe. Fan
t. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. Jam
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
Entities connected to both Little St. and the State of New York

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Federal Reserve
ORGANIZATIONDarren Indyke
PERSON
George W. Bush
PERSON
New York
LOCATIONLeon Black
PERSON
New York City
LOCATION
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATIONJane Doe
PERSON
Financial Trust Company
ORGANIZATION
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
New York State
LOCATION
Bradley Edwards
PERSON
Prince Andrew
PERSON
Richard Kahn
PERSON