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

intiffs' pleading, the First Amended Complaint does not provide any reference to the statutory underpinnings for the subject matter jurisdiction of the Superior Court, 4 V.I.C.§ 76, nor should it be Defendant's responsibility to select Plaintiffs' best weapon in this regard for any response. Subject matter jurisdi

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

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

ly chose not to do so. That they 3 EFTA00308341 Plaintif/i• Opposition to Defendant's Motion For Leave to File Amended Reply Epstein et al. vs. Falwell, Paneling, Inc. Case No. ST-10-CV-443 subsequently choose to do so now in violation of the rules of the Court should not be countenanced. II. DE

filed in violation of LRCi 7.1 and should therefore be rejected by this Court and stricken from the record. Since there is no electronic filing in the Superior Court, the undersigned can only be guided by the date on the pleading's certificate of service as to when the motion was filed with the Court. Defendant'