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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
nd Defendant's other attempts to dispute the allegations of Plaintiffs' FAC must be construed in Plaintiffs' favor. Metcalfe. 566 F3d at 330 citing O'Connor vs. Sandy Lane Hotel Co., 496 F.3d 312, 316 (3d Cir. 2007). I. Defendant Fancelli Paneling, Inc. Transacted Business in the Territory. This Court
laced. In the Amended 1999 Note, the parties stipu- lated only that IOUs note shall be governed by, and construed in accordance with, the laws of the State of New York, including matters of construction, validity and per- formance, without giving effect to princi- ples of conflicts of law .... (Mem. Of Law in Supp
depositions, this Court has the power and duty under Fed. R. Civ. P. 26(c) to determine the most appropriate location for each deposition. See e.g., O'Connor.. Trans Union Corp., 1998 U.S. Dist. LEXIS 6774 (E.D. Pa. May 11, 1998). This Court has previously determined "that as a general rule, if a deponen
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
r a United States Attorney to conduct an investigation or to initiate a prosecution because it would violate the doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D. Nev. 1981) (citing United States v. Cox, 342 F.2d 167, 171 (5th Cir. 1965)15 ("Although as a member of the bar,
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
r a United States Attorney to conduct an investigation or to initiate a prosecution because it would violate the doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D. Nev. 1981) (citing United States v. Cox, 342 F.2d 167, 171 (5th Cir. 1965)15 ("Although as a member of the bar,
Sponsoring Attorney form.pdf Page 9500 EFTA00042011 STATEMENT OF SPONSORING AT oRNEY I hereby certify that I am a licensed member of the bar of the State of New York and that I employ or supervise Joseph O'Brien I authorize Joseph O'Brien to represent me and request that as my representative she/he be allowed
Allison Bradley Gross Chris Bina, Darrin Hammon David Shinn Gene To Beasley, Jeffery Keller, Wills, Kenneth H le Michael Carvajal, Patrick'. O'Connor, Shaina Vanek Date 2019/08/26 11:44 Subject: Noteworthy News Articles 8.26.2019 Attachments: TEXT.htm Page 9502 EFTA00042013 Psychologist
rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio
a United States Attorney to conduct an investigation or to initiate a prosecution because it would violate the doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D. Nev. 1981) (citing United States v. Cox, 342 F.2d 167, 171 (5th Cir. 1965)15 ("Although as a member of the bar,
ll times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, , was an adult female. 9. At all times material to this cause of action, the Defe
r a United States Attorney to conduct an investigation or to initiate a prosecution because it would violate the doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D. Nev. 1981) (citing United States v. Cox, 342 F.2d 167, 171 (5th Cir. 1965)15 ("Although as a member of the bar,
Entities connected to both the State of New York and O'Connor

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Newark
LOCATIONDarren Indyke
PERSON
George W. Bush
PERSON
New York
LOCATIONLeon Black
PERSONthe Southern District
LOCATIONJersey City
LOCATION
New York City
LOCATIONJane Doe
PERSON
Samantha Power
PERSON
Alan Dershowitz
PERSON
U.S. Virgin Islands
LOCATION
Scarlett Johansson
PERSON
Julie K. Brown
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON