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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
ntacts with the Territory: That Plaintiffs learned of Fancelli after they engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
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
NQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
d States Virgin Islands applicable to agreements entered into entirely within the United States Virgin Islands, without regard to the principles of United States Virgin Island law regarding conflicts of laws. 18. Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the
THIS AGREEMENT, entered into this day of May, 2009, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux")), L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"). WHEREAS, disputes have arisen between Mol
y provide substantial grounds for civil claims against Mr. Molyneux and his firm, including, among other things, claims for fraud and violations of the Virgin Islands CICO statute. As I have informed you, Mr. Epstein intends to commence legal action in the Virgin Islands against Mr. Molyneux, his firm, and Fanceili, a
d shall not be admissible for any purposes in any litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneux Studio, Ltd., among others. Please be advised that nothing provided by this letter is intended or should be construed as a waiver by my clients of any rig
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
stein, et al. 1340 Taameberg St. Thomas, V.L 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES 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
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
ein, et al. 1340 Taarneberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES 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
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
tein, et al. 1340 Taameberg St. Thomas, V.I. 00802 PHONE: FAX: EMAIL: A. Jeffrey Weiss, Esquire A.J. WEISS & ASSOCIATES 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 Defe
Entities connected to both U.S. Virgin Islands and J.P. Molyneux Studio

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
Prince Charles
PERSONthe State of New York
LOCATIONV.I.C.
ORGANIZATIONSuperior Court
ORGANIZATIONL.S.J.
ORGANIZATION
Little St. James Island
LOCATION
Little St. James
ORGANIZATION
V.I.
LOCATION
Little St.
LOCATIONJuan Pablo Molyneux
PERSONDenise Francois
PERSONFancelli
PERSON
Russell Simmons
PERSONJames Island
LOCATIONTreston E. Moore
PERSONthe Superior Court
ORGANIZATIONMOORE DODSON & RUSSELL
ORGANIZATION