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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
aused a true and correct copy of the foregoing Plaintiff's Opposition to Defendant's Motion to Dismiss to be served upon Treston E. Moore, Esquire, MOORE DODSON & RUSSELL, P. O. Box 310, St. Thomas, VI 00804 by first class U. S. Mail, postage prepaid on this 11'" day of February, 2011. bb K1/4 BRAD. 4 C( 30 EFTA003
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
h other and further relief as the Court deems just and proper. alb Dated this /1, th day of March, 2011. Respectfully s Treston E V.I. Bar 10 MOORE DODSON & RUSSELL, P.C. Attorneys for Defendant 5035 Noire Gad; P.O. Box 310 St. Thomas, VI 00804-0310 PHONE: FAX: EMAIL: CERTIFICATE OF SERVICE I hereby certif
as set the jury selection and trial in this matter for December 3, 2012. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EXHIBIT 1 EFTA00602425 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 26W Epstein. et al. v. Fancelli Paneling. Inc., et al. Page 4 Re
SOCIATES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.L 00802 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defendant Fancelli Paneling, Inc. P.O. Box 310, E.G.S. (I4A Norre Gade) St. Thomas, VI 00804-0310 PHONE: FAX: EMAIL: (340) 7
as set the jury selection and trial in this matter for December 3, 2012. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EFTA00614298 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 260) Epstein, et al. v. Fancelli Paneling, Inc., et al. Page 4 Respectfully
OCIATES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defendant Fancelli Paneling, Inc. P.O. Box 310, E.G.S. (14A None Gade) St. Thomas, VI 00804-0310 PHONE: FAX: EMAIL: EFTA0061
has set the final pretrial conference for November 9, 2012 at 9:30 a.m. 2 A majority of parties and witnesses in this action reside outside of the U.S. Virgin Islands. EFTA00616775 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 260) Epstein, et aL v. Fancelli Paneling, Inc., et aL Page 4 7. The Court
ES Counsel for Defendant J.P. Molyneux Studio, Ltd. 6934 Vessup Lane St. Thomas, V.I. 00802-1001 PHONE: FAX: EMAIL: Treston E. Moore, Esquire MOORE DODSON & RUSSELL, P.C. Counsel for Defendant Fancelli Paneling, Inc. P.O. Box 310, E.G.S. (14A Norre Gade) St. Thomas, V PHONE: FAX: EMAIL: EFTA00616776
Entities connected to both U.S. Virgin Islands and MOORE DODSON & RUSSELL

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
Puerto Rico
LOCATION
Prince Charles
PERSON
New York State
LOCATION
Scarlett Johansson
PERSONthe State of New York
LOCATIONV.I.C.
ORGANIZATION
St. John
LOCATIONSuperior Court
ORGANIZATION
Saint James
LOCATION
James Baker
PERSON
Little St. James Island
LOCATION
V.I.
LOCATIONDenise Francois
PERSONFancelli
PERSON
Russell Simmons
PERSONJuan Pablo Molyneux
PERSONTreston E. Moore
PERSON