Epstein Secrets

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

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

victims of his crimes, like Jane Doe, can obtain recovery for all the harm that he caused them. THE PARTIES 7. Plaintiff Jane Doe is a citizen of the State of New York. At all times relevant to this suit, Doe was a minor child living in New York City. 8. Defendant Darren K. Indyke is sued in his capacity as an ap

er situated...to the then acting Trustees of The 1953 Trust." 67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the Ma

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

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

minor child living in and who was sexually abused while she was a minor by Defendants in New York. 5. Defendant Ghislaine Maxwell is domiciled in the State of New York. 6. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. 7. Defendant Richard D. Kah

3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistr

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

iminal Activity Lien Notice pursuant to Chapter 30, Title 14 § 610, in the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of