Epstein Secrets

led himself of the benefits and protections of the EFTA00310011 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS &stein. et at v. Falwell' Paneling. Inc. Page laws of the forum state." Burger King Corp., 471 U.S. at 474-476. The purposeful availment requirement "ensures that a defend

hat the whole of this dispute blossoms from an agreement made in New York between Plaintiff Epstein (wherever he was residing in 2005) and Molyneux (New York), then an agreement between Molyneux and Fancelli (New York). It is respectfully submitted that the law of the State of New York will be operative t

ent or through service upon the Secretary of State. In addition, Fancelli argues that it is not a citizen or resident of the Virgin Islands, does 2 Falwell' alleges In Its Motion to Dismiss that Epstein is also a resident of New York, NY, and Palm Beach, Florida. However, the Court accepts as true the n

t the better and proper venue for this action is New York because most of the people with information or knowledge of these events reside in France, New York, and Italy, and because most of the documents relevant to this cause are located in those regions. For the reasons that follow, the Court will deny

inst Defendant for failure to correct the multitude of 27 EFTA00309207 Plaintiffs' Opposition to Defendant's Motion to Dismiss Epstein et al. it Falwell' Paneling. Inc. Case No. ST-I0-CV-443 defects in and to properly and fully complete the fabrication, installation, staining and finishing of the L

r confirms, under oath, that Fancelli Paneling, Inc. was served with the summons and the FAC at its business address located at 24 East 64th Street, New York, NY 10021, in care of its president, Mr. Jean Pierre Fancelli, through Mr. Christian Barthod who verified to the process server that he worked at Fa