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

int with Points and Authorities should be denied in its entirety. Respectfully submitted, HODGE AND FRANCOIS Dated: Z ( 1 1 1 2-O11 By: setWAYD Denise Francois V.I. Bar Association #285 1340 Taameberg St. Thomas, VI 00802 Tel. (340) 774-6845 Fax. (340) 776-7720 Email: [email protected] Attorneys

ph 16(8). (C) This Agreement and the rights of the parties hereunder will be governed by, interpreted and enforced in accordance with the laws of the United Stater Virgin Islands, without regard to principles of conflicts of laws. (D) This Agreement shall :nun to the benefit of and bind the parties hereto, their respective

operate and/or, if and when nenccary or appropriate, sell or otherwise dispose of the Company Property (or any portion thereof), whether located in the U.S. Virgin Islands or elsewhere, and other real and personal property of any kind or nature and to engage in any and all activities incidental or related to the foreg

REAS, a limited liability company has been famed under the name THOMAS WORLD AIR, LLC for the purposes set forth in Paragraph 4 hereerC pursuant to the United States Virgin Islands Uniform limited Liability Company Act (fide 13 of the Virgin Islands Code, Chapta 15, § 1101 at seq. (1998)), as amended (the "Ace), and other applicable l

LC for the purposes set forth in Paragraph 4 hereerC pursuant to the United States Virgin Islands Uniform limited Liability Company Act (fide 13 of the Virgin Islands Code, Chapta 15, § 1101 at seq. (1998)), as amended (the "Ace), and other applicable laws of the United States Virgin Islands; and WHEREAS, the undersig

St. Thomas, VI 00802. The resident agent of the Company (the "Resident Agent") in the United States Virgin Islands for service of process shall be Denise Francois, who is a resident of the United States Virgin Islands, or such other person as may be designated by the Members. The address of the Resident Agent

tion have not been filed by the company. In Witness Whereof, I have hereunto set my hand and affix the seal of the Government of the United States Virgin Islards, at Charlotte Amalie, this 3rd day of December. A.D. 2015. OSBERT E. POTTER Lieutenant Governor of the Virgin Islands CONFIDENTIAL FerstBankPROO

perate and/or, if and when necessary or appropriate, sell or otherwise dispose of the Company Property (or any portion thereof), whether located in the U.S. Virgin Islands or elsewhere, and other real and personal property of my kind or nature and to engage in any and all activities incidental or related to the forego

irgin Islands. does hereby consent to act as such agent. and that service of process may be made upon me in accordance with Chapter 15. Title 13 nf the Virgin Islands Code. IN WITNESS WHEREOF. I have hernial° set my signature thister4ay or UcCAA- "\.. , CIALC .0(0 Denise I-Fel:cols. lure HODGE & FRANCOIS 1340 Taa

, St. Thomas, VI00802. The resident agent of the Company (the "Resident Agent") in the United States Virgin Islands for service of process shall be Denise Francois, who is a resident of the United States Virgin Islands, or such other pence as may be designated by the Members. The address of the Resident Agent

e Ann. tit. 4, § 76(a). 6. Venue is proper in the judicial district of St. Thomas and St. John because the Plaintiffs are residents of St. Thomas, U. S. Virgin Islands, and the cause of action arose in the judicial district of St. Thomas and St. John. Count I Fraud 7. In or about December, 2010, based upon repr

omplaint against the Defendants, Nick Lambros and AVLC, LLC, state the following:, 1. The Plaintiff, Jeffrey Epstein ("Epstein"), is a resident of the United States Virgin Islands and is the sole member of L.S.J., LLC. 2. The Plaintiff, L.S.J., LLC ("LS.1"), is a limited liability company organized under the laws of the Stat

ent for installation at multiple locations in a large-scale, multi-structure, multi-million dollar residence on Little Saint James Island located in the U. S. Virgin Islands, as well as a luxury townhouse in New York City. 8. Based upon representations made by Lambros, Plaintiffs paid Lambros over one Hundred Thirty F

relief as this Court may deem just, proper and reasonable. 5 EFTA00299480 Complaint Epstein v. Lambros et at. Respectfully submitted, Dated: Denise Francois, Esquire V.I. Bar Association #285 HODGE & FRANCOIS 1340 Taarneberg St. Thomas, VI 00802 Telephone: Telefax: EFTA00299481

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

ATE OF SERVICE I hereby certify that on this lath day of March, 2011, a copy of the foregoing was served by first class mail, postage prepaid, upon Denise Francois, Esquire, Hodge & Francois, #1340 Taarneberg, St. Thomas, V.I. 00802. EFTA00310017 § 308. CPLR effective unless the front .of the envelope bear

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

OF COUNSEL PURSUANT TO RULE 26W Epstein. et al. v. Fancelli Paneling. Inc., et al. Page 4 Respectfully submitted, Dated this day of July, 2012. Denise Francois, Esquire HODGE & FRANCOIS Counsel for Plaintiff Epstein, et al. 1340 Taameberg St. Thomas, V.L 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esq

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

COUNSEL PURSUANT TO RULE 260) Epstein, et al. v. Fancelli Paneling, Inc., et al. Page 4 Respectfully submitted, Dated this " day of July, 2012. Denise Francois, Esquire HODGE & FRANCOIS Counsel for Plaintiff Epstein, et al. 1340 Taarneberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, E

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

4 7. The Court has set the jury selection and trial in this matter for December 3, 2012. Respectfully submitted, Dated this day of July, 2012. Denise Francois, Esquire HODGE & FRANCOIS Counsel for Plaintiff Epstein, et al. 1340 Taameberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Es