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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
)(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
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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 throughout this litigation on matters sounding in contract and, to a lessor extent, derivative matters of negligence as well. Alt
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
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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
te' then '[1]ittle doubt remains that such an intangible interest is property protected by the Fourteenth Amendment.— In re the Estate of Small, 57 V.I. at 423 (quoting Tulsa Profl Collection Serv.. Inc•. v. Pope, 485 U.S. 478, 485, 108 S. Ct. 1340, 1345 (1988)). III. ANALYSIS Pursuant to Rule 24
Sponsored
Mutual Connections (143)
Entities connected to both the State of New York and V.I.
Jeffrey Epstein
PERSON472 w/ the·53 w/ V.I.
JPMorgan Chase
ORGANIZATION289 w/ the·3 w/ V.I.
Ghislaine Maxwell
PERSON209 w/ the·8 w/ V.I.
Newark
LOCATION175 w/ the·2 w/ V.I.
United States
LOCATION162 w/ the·8 w/ V.I.
DI
Darren Indyke
PERSON130 w/ the·7 w/ V.I.
George W. Bush
PERSON104 w/ the·19 w/ V.I.
New York
LOCATION93 w/ the·10 w/ V.I.
LB
Leon Black
PERSON88 w/ the·7 w/ V.I.
New York City
LOCATION88 w/ the·5 w/ V.I.
Samantha Power
PERSON77 w/ the·7 w/ V.I.
U.S. Virgin Islands
LOCATION62 w/ the·19 w/ V.I.
the Southern District
LOCATION75 w/ the·4 w/ V.I.
JD
Jane Doe
PERSON64 w/ the·2 w/ V.I.
Alan Dershowitz
PERSON57 w/ the·9 w/ V.I.
Financial Trust Company
ORGANIZATION59 w/ the·4 w/ V.I.
Kenneth Marra
PERSON53 w/ the·5 w/ V.I.
New York State
LOCATION51 w/ the·2 w/ V.I.
Joi Ito
PERSON43 w/ the·6 w/ V.I.
Scarlett Johansson
PERSON44 w/ the·4 w/ V.I.