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and Defendant can thereafter admit, or deny the specifics of same. Personal jurisdiction alleged through some subsection of the long-arm statute, 5 V.I.C. § 4903, over this non-resident Defendant was not affirmatively plead in the First Amended Complaint-it is argued in opposition to the Motion to Dism
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
rned to the Territory on multiple occasions from May 2009 to March 2010 to resume the installation. FAC ¶9 and P1. Ex. 8 Affidavit of Gary Kerney. 5 V.I.C. § 4903(a)(1). Defendant's conduct rose to the level of doing business and was more than a consequential act. Bertrand v. Cordiner at *17 citing Man
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
ital homestead,' both the United States Court of Appeals for the Third Circuit and the Appellate Division of the District Court interpreted Title 33 V.I.C. §§ 2305(a), (c) to hold that a "marital homestead' is any 'homestead' [98] in which a husband and wife both reside during the marriage and that is
ans of time during which the parties did not occupy it together." 59 V.I. 758 (V.I. 2013). Ultimately, the Garcia Court remanded the matter back to the Superior Court for further consideration without determining which units comprised the marital abode. Here, the Solberg property is apportioned into three (3) uni
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
ed and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial docu
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
ed and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial docu
he approval of any claim by the Program Administrator will be deemed to have the effect of a claim "examined and approved" within the meaning of 15 V.I.C. § 394. D. CREDENTIALS OF PROGRAM ADMINISTRATOR AND DESIGNERS The Program Administrator and Program Designers' qualifications for participation in
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
Entities connected to both V.I.C. and the Superior Court

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
Sarah Ferguson
PERSON
New York
LOCATION
United States
LOCATION
Richard Kahn
PERSON
George W. Bush
PERSON
Woody Allen
PERSON
St. John
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe State of New York
LOCATION
Condoleezza Rice
PERSONthe Superior Court of the Virgin Islands
ORGANIZATION
Prince Charles
PERSON
V.I.
LOCATION
Legislature
ORGANIZATION
Prince Andrew
PERSONSouthern District
LOCATION