Epstein Secrets

. ST-10-O4443 4. The undersigned counsel's office has either an office employee or an independent courier check the Hodge & Francois "mailbox- at the Superior Court at least once a day, and as of May 26, 2011 the undersigned counsel had not received any Orders or the Memorandum Opinion from the Court that the d

d. as a party to the above-captioned action. A proposed form of order is attached for the Court's consideration. Respectfully submitted, HODGE AND FRANCOIS Dated: 6 (3I I 2-O11 By: ?I &(.t. O Denise Francois V.I. Bar Association #285 1340 Taarneberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (

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

e, the Defendant's Motion to Dismiss the Complaint 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)

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'

endant require the denial of Defendant's Motion to Dismiss which has evolved into a Motion for Summary Judgment. Respectfully submitted, HODGE AND FRANCOIS Dated: 3129 (2-01 1 By: Denise Francois aLcusiki Tel. Fax. ( Emai Attorneys for Jeffrey Epstein and L.SJ., LLC 8 EFTA00308346 Plaintiffs'