Epstein Secrets

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

to the non-movant, Defendant's Motion to Dismiss the Complaint with Points and Authorities should be denied in its entirety. Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Ashcroft v. !Oat 556 U.S. , 129 S. Ct. 1937 (2009), Fowler v. UPMC Shadyside, 578 F.3d 203, 210- 211 (3r° Cir. 2009) (quoting

t forth, above, this case lacks merit and should be dismissed no matter where it is filed. Having said that, and as you know, Epstein resides in the U.S. Virgin Islands, where the court has personal jurisdiction over him. Moreover, the other Defendants are all located in states other than New York and no significant

raud based claims, it also fails to meet the more relaxed pleading standards set forth by the United States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007) and Ashcroft v. Igbal, 129 S.Ct. 1937 (2009). These two decisions set forth the basic requirements for pleading a claim. As

n paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in P

a suspicion of a legally cognizable right of action,'" Hell Atlantic Corn. 1 Twomblv, 550 U.S. 544, 555 (2007), and just last week made clear that "Twombly expounded the pleading standard for 'all civil actions' and not just pleadings made in the context of an antitrust dispute," Ashcroft'. Iqbal No. 0

n Found Non-Negative Media: No Information Found Other Language Media: No Information Found Public Record: Mort, Inc City:St, Thomas Country: NArgin Islands, U.s. NCA customised Auto-Closed No-Hit 02/10/2015 1 OF 2 RECORD(S) Comprehensive Business Report Report Created:10.01-2015 6:17 PM EST I FOR INF

to survive a motion to dismiss, a complaint must allege facts that raise a right to relief above the speculative level. [94] Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007); see also Fed. R. Civ. P. 8(a)(2). When considering a Rule 12(b)(6) motion, the revie

t forth, above, this case lacks merit and should be dismissed no matter where it is filed. Having said that, and as you know, Epstein resides in the U.S. Virgin Islands, where the court has personal jurisdiction over him. Moreover, the other Defendants are all located in states other than New York and no significant

78 Brad Edwards, Esq. May 15, 2017 Page 3 Steptoe ccc ot a toottsiTto tto statutes it is relying on. Finally, the Complaint fails to meet the Twombly/Iqbal standard for pleading any claim in federal court. A. The Complaint Fails to Plead Fraud Plaintiff's claim that the Defendants used "fraud" t

der to coerce the plaintiff into compliance. Amended complaint paragraph 48 and 50. For example, while being transported to Epstein's island in the U.S. Virgin Islands, Epstein, Maxwell, and took possession of the plaintiff's passport in order to coerce her to comply with their demands, including their demands th

not dismiss the complaint if the plaintiff has stated "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 554, 570 (2007). "A claim has SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285671 42 I877DOEC facial plausibility when the