Epstein Secrets

)(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

int with Points and Authorities should be denied in its entirety. Respectfully submitted, HODGE AND FRANCOIS Dated: Z ( 1 1 1 2-O11 By: setWAYD Denise Francois V.I. Bar Association #285 1340 Taameberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (340) 776-7720 Email: [email protected] Attorneys

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

ATE OF SERVICE I hereby certify that on this lath day of March, 2011, a copy of the foregoing was served by first class mail, postage prepaid, upon Denise Francois, Esquire, Hodge & Francois, #1340 Taarneberg, St. Thomas, V.I. 00802. EFTA00310017 § 308. CPLR effective unless the front .of the envelope bear

trict Cowl, the Ocderal Rules of Civil Procedure, the Federal Rules of Criminal Procedure and the Federal Rules of Evidence." ° Bostic v. AT&T ophe V.I., 312 F. Supp. 2d 731, 733 (D.V.I. 2004). 9 Harsco Corp. v. Zlotnicki, 779 F.2d 906, 909 (3d Cir. 1985). 1° F & M Distributors, Inc. v. American Har

Upon discovering various deficiencies in Fancelli's work, Plaintiffs, as third party I Plaintiffs Jeffrey Epstein and L.S.J., LLC are represented by Denise Francois, Esq. Defendant Fancelli P eling, Inc., is represented by Treston E. Moore, Esq. 2 For a complete recitation of the factual and procedural history