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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
NQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
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
ach of contract and negligence. Subsequent y, on December 30, 2010, Plaintiffs entered into a "Confidential Agreement" with Juan ablo Molyneux and J.P. Molyneux Studio, Ltd. in which the parties provided one another with g' releases with respect to events relating to the Little St. James Project. In its May 16, 20
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
ntacts with the Territory: That Plaintiffs learned of Fancelli after they engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
Entities connected to both the Superior Court and J.P. Molyneux Studio

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSONJuan Pablo Molyneux
PERSONTreston E. Moore
PERSONDenise Francois
PERSONFancelli
PERSONthe State of New York
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATIONV.I.C.
ORGANIZATION
New York
LOCATION
V.I.
LOCATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATION
Falwell
PERSON
Prince Charles
PERSONV.I. Bar Association
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATION
Little St. James Island
LOCATIONBarthod
PERSON