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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
rnish and cause to be properly installed and completed at the Office Pavilion by January 2, 2020 all of the items listed on Exhibit hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010, Molyneux agrees that the' aggregate amount to be applied against the Cre
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
n contracted with Molyneux for the architecture and design of the interior and exterior of a separate building on Little Saint James Island known as the Office Pavilion." FAC„ para. 4, p. 2. They also state that Plaintiff L.S.J., LLC, is the owner of Little St. James Island. See Neitzke v. Williams, 490 U.S. 319, 3
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
ettlement Agreement between our respective clients, all of which are hereby expressly reserved. There are numerous uncorrectable issues relating to the Office Pavilion, which remains unfinished almost a full year after the parties entered into their settlement agreement and more than four years after Mr. Molyneux
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
ish and cause to be properly installed and completed at the Office Pavilion by January 1, 2010 all of the items listed on Exhibit B hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010. Molyneux agrees that the' aggregate amount to be applied against the Cre
Entities connected to both U.S. Virgin Islands and the Office Pavilion

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSONthe State of New York
LOCATION
Condoleezza Rice
PERSON
Saint James
LOCATION
Sergey Brin
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSONBrice Gordon
PERSON
White House
ORGANIZATIONDoug Schoettle
PERSONJ.P. Molyneux Studio
PERSONDenise Francois
PERSON
Patty
PERSONRoyal Dane
ORGANIZATIONthe Territory of the
LOCATIONSt James Island
LOCATIONMOORE DODSON & RUSSELL
ORGANIZATION