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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
EFTA00310009 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS Epstein. et aL v. Fanelli Paneling. Inc. Page 7 statute within its First Amended Complaint. Nevertheless, this statute is lustily utilized in opposing Defendant's Motion to Dismiss on point, to the extend that 5 V.I.C. § 4903(a)(I) & (2)
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
frey 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 documents in this action has already been granted to intervening private parties in interest, s
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
frey 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 documents in this action has already been granted to intervening private parties in interest, s
Entities connected to both V.I.C. and First Amended Complaint

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
United States
LOCATION
New York
LOCATION
Ghislaine Maxwell
PERSONJack Goldberger
PERSONthe State of New York
LOCATION
Condoleezza Rice
PERSON
Prince Charles
PERSONJane Doe
PERSON
Scarlett Johansson
PERSON
Deutsche Bank
ORGANIZATION
Legislature
ORGANIZATION
Saint James
LOCATION
Alan Dershowitz
PERSONthe Superior Court
ORGANIZATION
Virginia Giuffre
PERSONMotley Rice
PERSON
Supreme Court
ORGANIZATION