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

. was served with the summons and the FAC at its business address located at 24 East 64th Street, New York, NY 10021, in care of its president, Mr. Jean Pierre Fancelli, through Mr. Christian Barthod who verified to the process server that he worked at Fancelli Paneling, Inc. Defendant never argues that the summons

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

According to Plaintiffs, Fancelli's agents were on Little St. James a number of times in order to complete the installation? Fancelli's president, Jean Pierre Fancelli ("Mr. Fancelli"), was on St. Thomas and Little St. James in January and March 2010. Plaintiffs allege that Fancelli understood that its constructi

S JURY TRIAL DEMANDED AFFIDAVIT Denise Francois, after being duly sworn deposes and says: 1. That I am an attorney authorized to practice law in the United States Virgin Islands, and a partner in the law firm of Hodge & Francois, legal counsel of record for the Plaintiffs Jeffrey Epstein and L.S.J., LLC (the "Plaintiffs") in

any of their respective joint or several obligations under the Agreement or the Office Design Agreement, and nothing provided herein shall release Jean Pierre Fancelli, Fancelli Paneling, Inc., Fancelli Studios, Atelier Fancelli, or any entity affiliated or otherwise associated with any Fancelli entity ("collectiv