3
Shared Docs
3
Same-Page
3 / 4
Mentions
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
)(1). Defendant's conduct rose to the level of doing business and was more than a consequential act. Bertrand v. Cordiner at *17 citing Manbodh, 47 V.I. at 283 and Hendrickson v. Reg 0 Co., 17 V.I. 457, 462 (D.V.I. 1980). Even a single act amounting to "transaction of business" in the Territory may
m contacts with the forum that "the maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.'" Godfrey, 18 V.I. at 68-69 (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). In evaluating whether the exercise of jurisdiction is fair and re
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
he party asserting personal jurisdiction, has the burden of establishing it." Evans v. General Gases of Y.I., Inc.. 1998 WL 912544 *1, *2 (Terr. Ct. V.I. Nov. 30, 1998). A. LONG-ARM JURISDICTION It must be conceded at the outset that Plaintiffs' failed to reference the V.I. long-arm EFTA00310009 DE
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
V.I.C. § 4903(a)(1). Berrran4 2010 WI, 2507305, at '9 (citing Metcalfe v. Renaissance Marine, Inc., 566 F.3d 324, 332 (3d Cir. 009)). Aftrnbook 47 V.I. at 283; see also Ifendrickson v. Reg 0 Co., 17 V.L 457, 462 (D.V.I. 1980). Afruccife, 566 F.3d at 332 ("Mhe Metcalfe: assert that Renaissance exchan
Entities connected to both Falwell and V.I.

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATION
St. John
LOCATION
New York
LOCATIONV.I.C.
ORGANIZATION
Alan Dershowitz
PERSON
Prince Charles
PERSONFancelli
PERSON
Russell Simmons
PERSONthe Superior Court
ORGANIZATION
Vicky Ward
PERSON
Julie K. Brown
PERSONthe State of New York
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATIONDenise Francois
PERSONJ.P. Molyneux Studio
PERSON
Supreme Court
ORGANIZATIONBertrand
PERSON
Metcalfe
PERSON
Little St. James Island
LOCATION