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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
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
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
hat agreement and the reasonable expectations .of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
ux is a world-renowned interior designer. 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. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was const
n of the Design Services Agreement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman, undertook to and did perform the Exhibit B Services, with the exception of the restaining and refinishing of the wood cabinetry. On January 26 and 27, 2010, Plaintiffs travelled to Little Saint Jame
rmation and belief, the remaining Defendant, L.SJ., 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
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
Entities connected to both U.S. Virgin Islands and the Exhibit B Services

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATIONthe State of New York
LOCATION
Saint James
LOCATION
Russell Simmons
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSONDenise Francois
PERSONMOORE DODSON & RUSSELL
ORGANIZATIONthe Territory of the
LOCATION
Patty
PERSONRoyal Dane
ORGANIZATIONthe Office Pavilion
ORGANIZATIONStudio
PERSONJay Goldberg
PERSONVI Bar No
ORGANIZATIONRosh D. Alger Esquire
PERSONAdjudging
LOCATIONthe District Court of the Virgin Islands
ORGANIZATION