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

.2d at 233. Unambiguous con- tractual language is not rendered ambiguous "simply because the parties urge different interpretations in litigation." Sterling, 792 F.Supp. at 1366. Moreover, whether a con- tract is ambiguous is to be determined by considering the contract as a whole. Wing Wing, 112 A.D.2

ury: • That he is President and Director of Financial Trust Company, Inc., a business that provides financial and business consulting services from the U.S. Virgin Islands to its clients. Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 7 of 26 CAS

contest Jane Doe’s argument that “equity will do what ought to be done.” Jane Doe’s Motion to Restrain Fraudulent Transfer of Assets at 17 (citing Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000)). The only question then is “what ought to be done?” Case 9:08-cv-80119-KAM Document

Document 165 Entered on FLSD Docket 06/19/2009 Page 23 of 41 Epstein and Col, later called Financial Trust Co., located on his private island in the U.S. Virgin Island. He reportedly only took billionaire clients. - 3. Other attorneys and I have made repeated efforts to find published information about defendant Je

ght to 17 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 18 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedi