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

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

f among the existing parties." 7 Superior Court Rule 7 states that "the practice and procedure in the Superior Court shall be governed by Rules of the Superior Court and, to the extent not inconsistent therewith, by the Rules of the District Cowl, the Ocderal Rules of Civil Procedure, the Federal Rules of Crimina

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

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

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