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

nd says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York (-Studio"). 3. In 2005, Jeffrey Epstein ("Epstein")

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

.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, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little St. James. Molyneux has offices in New York, New York

mation and belief, the remaining Defendant, L.S.J., LLC, is organized in the State of Delaware and maintains its principal place of business within the U.S. Virgin Islands. 5. This Court has original jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000, exclu

e with the laws of the Virgin Islands applicable to agreements entered Into entirely within the Virgin Islands, without regard to the principles of Virgin Islands' law regarding conflicts of ;mks. 19. Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the

Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by and throu

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

cutors and administrators (collectively, the "Epstein Releasors") hereby fully and irrevocably release each of JP [Juan Pablo Molyneux] and Studio [J.P. Molyneux Studio, Ltd.], and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the "Molyneux Releasees"), of and from any