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trict Court of the Virgin Islands for damages sustained as a result of the loss of their goods. After finding that Ocean-Air's activities within the Virgin Islands constituted transacting business within the Territory and contracting to supply services or things in this Territory within the meaning of subsectio
LANDS ARE THE CORRECT FORUM FOR PLAINTIFFS' CAUSES OF ACTION AGAINST DEFENDANT. Ignoring the facts that: Plaintiff Jeffrey Epstein is a resident of the United States Virgin Islands with his home on Little Saint James Island; L.S.J., LLC, which is solely owned by a United States Virgin Islands resident and maintains its principa
fs' FAC, the factual allegations of which must be accepted as true and construed in the light most favorable to the Plaintiffs, clearly establishes the Virgin Islands' overwhelming local interest in this controversy. The controversy is of local interest in the Virgin Islands and localized interest rests with the V
ended by Studio and Fancelli when they contracted that the Library Cabinetry was to be installed and used in an office/library structure located in the United States Virgin islands and would be therefore subject to temperature and humidity levels inherent in a Caribbean climate, as well as within an office structure in
inst Defendant for failure to correct the multitude of 27 EFTA00309207 Plaintiffs' Opposition to Defendant's Motion to Dismiss Epstein et al. it Falwell' Paneling. Inc. Case No. ST-I0-CV-443 defects in and to properly and fully complete the fabrication, installation, staining and finishing of the L
Paneling Inc. Civil No. ST-10-CV-443 Memorandum Opinion Page 2 of 11 FACTUAL AND PROCEDURAL BACKGROUND Plaintiff Jeffrey Epstein, a resident of the Virgin Islands,2 is the sole member of Plaintiff L.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, E
nstallation of the cabinets, in performance of its contract with Molyneux, were to benefit Epstein and L.S.J., and would be used in a library in the Virgin Islands.' On July 30, 2010, Plaintiffs filed the Complaint in this action, alleging that the cabinetry installation had not been properly completed, that t
iction is proper under section 4903(a)(2). All that is required to satisfy section 4903(a)(2) is that a "contract be performed, at least in part, in the virgin Islands and that the cause of action arise out of the contract."31 If a defendant knows that the ultimate destination of its goods will be the Virgin Island
ent or through service upon the Secretary of State. In addition, Fancelli argues that it is not a citizen or resident of the Virgin Islands, does 2 Falwell' alleges In Its Motion to Dismiss that Epstein is also a resident of New York, NY, and Palm Beach, Florida. However, the Court accepts as true the n
a world-renowned interior designer. . 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was c
led himself of the benefits and protections of the EFTA00310011 DEFENDANT'S REPLY TO PLAINTIFFS' OPPOSITION TO MOTION TO DISMISS &stein. et at v. Falwell' Paneling. Inc. Page laws of the forum state." Burger King Corp., 471 U.S. at 474-476. The purposeful availment requirement "ensures that a defend
Entities connected to both U.S. Virgin Islands and Falwell

Jeffrey Epstein
PERSON
New York
LOCATION
Alan Dershowitz
PERSON
Julie K. Brown
PERSON
Prince Charles
PERSON
Vicky Ward
PERSONthe State of New York
LOCATIONV.I.C.
ORGANIZATION
St. John
LOCATION
Supreme Court
ORGANIZATION
Ashcroft
PERSON
Little St. James Island
LOCATION
V.I.
LOCATION
Russell Simmons
PERSONFancelli
PERSONDenise Francois
PERSONJuan Pablo Molyneux
PERSONthe Superior Court
ORGANIZATIONJ.P. Molyneux Studio
PERSONMOORE DODSON & RUSSELL
ORGANIZATION