Epstein Secrets

d until 2002, just months before the commencement of this litigation. On Jan- uary 31, 2002, Citibank closed its last re- maining bank branch in the U.S. Virgin Islands, and Citibank no longer makes real estate-related loans in the Virgin Islands. (Malin Aff. 11 3-4.) Citibank, however, continues to process its ou

ing the depositions for a date and time that is suitable for both the Defendants and Plaintiff, and relocating the depositions from Philadelphia to the U.S. Virgin Islands for Mr. Epstein and Ms. Maxwell; and New Albany, Ohio for the Wexners. Accordingly, this Court should grant Defendants' motion for a protective ord

fs counter that the defendants are currently doing busi- ness in the Virgin Islands and that this Court has jurisdiction over the defendants under the Virgin Islands' Long—Arm Stat- ute. The plaintiffs insist that the defen- dants' depiction of Citigroup as a "holding company" is belied by Citigroup's public disclosur

e that this Court has jurisdiction under the Virgin Islands Long-Arm Statute over both the defendants. 2. The Defendants' "Minimum Con- tacts" in the Virgin Islands Meet the Constitution's Due Process Re- quirements In addition to finding jurisdiction under this forum's long-arm statute, I must also determine whet

parties could come to a mutually agreeable date for the deposition. Plaintiff still, nearly three months later, has yet to agree to a date in which Shanks can be deposed, but has instead unilaterally designated September 9th and 10th in Philadelphia as the time and place for Defendants' depositions. D

. Or -"deb NOTED IN THE PUBLIC MRSTIOR'S RECORD FOR COUNTRY PRO' ER 1 • JK FOR It1 /4 7c LITTLE ST. tTAME$~j$LAjgp; ssuail iooluluART01),. ST. THOMAS VIRGIN ISLANDS WO% OE el cm t ean; ;sow& iprigie191 981 Lourriv e. eo,St' Ph -...qc 04741 /2 44,04.0•• As . li , A. sr 04, C Su . ,E;, E :4w 17ate

REQUE, MARY ALICE WOODRUFF, CHRISTIAN VOLLENTINE HANKS, JR., by their attorney-in-fact, CREQUE ESTATES,

onal Limited. Ferbel International was originally incorporated on April 25. 2003 in Bermuda. The company later changed its registered address to the British Virgin Islands on January 28, 2011. On December 18, 2013 the company transferred to Spain and changed its legal name to the current, Ferbel Group of Companies. S.

lts found 0 Yes K No Please summarize any negative results from the database searches indicated above: -Rrscosoft Alert for Jesus Armando Lema 0. Hanks who is Director of Aromatiss S.A. . His brother Rolando Enrique Lema Hanke was former Director General, of the Legal Advisory Office of the Ministry