Epstein Secrets

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

h other and further relief as the Court deems just and proper. alb Dated this /1, th day of March, 2011. Respectfully s Treston E V.I. Bar 10 MOORE DODSON & RUSSELL, P.C. Attorneys for Defendant 5035 Noire Gad; P.O. Box 310 St. Thomas, VI 00804-0310 PHONE: FAX: EMAIL: CERTIFICATE OF SERVICE I hereby certif

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

aused a true and correct copy of the foregoing Plaintiff's Opposition to Defendant's Motion to Dismiss to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this 11'" day of February, 2011. bb K1/4 BRAD. 4 C( 30 EFTA003

filed in violation of LRCi 7.1 and should therefore be rejected by this Court and stricken from the record. Since there is no electronic filing in the Superior Court, the undersigned can only be guided by the date on the pleading's certificate of service as to when the motion was filed with the Court. Defendant'

of the foregoing Plaintiffs' Opposition to Defendant's Motion for Leave to File An Amended Reply Brief to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this ,Qcrt- day of ?-La r rU. , 2011. PnottshIGA Anna_ It-t