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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
e, the Defendant's Motion to Dismiss the Complaint 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)
268921 • ARTICLES OF INCORPORATION OF PT PRAT RSTATP THE UNDERSIGNED INCORPORATORS, for the purpose of forming a corporation under the laws of the VUgin Islands and particularly Tide 13 of the Virgin islands Code, hereby adopt the following ARTICI PS OF LNCORPORATION for such corpontiont . . . _ . ARTICL
r tin of itieVisignisliisd - i;doett holdlebithrintlind as each agent,- and that service ofprocen maybemade upon me in accordance with Title IS of the Virgin Islands Code. IN INTINESS WEEREOP, I ham haramo set m a y signet= this tday of May, 2007fien _Sr i/ ifteld23 Maria TanIcemon Rod. g "" kyl ta) HODGE 14 FR
N OF THE UNDERSIGNED INCORPORATORS, for the purpose of forming a corporation under the laws of the Virgin Islands and particularly Title 13 of the Virgin Islands Code, hereby adopt the following ARTICLES OF INCORPORATION for such corporations ARTICLE ONE cs CD 4* • M V3 The name of the corporal= hereby
de. IN INTINESS WEEREOP, I ham haramo set m a y signet= this tday of May, 2007fien _Sr i/ ifteld23 Maria TanIcemon Rod. g "" kyl ta) HODGE 14 FRANCOIS .9 a ga s) 1340 Taanderg St. Thomas, VI 00802 g. a -2;,4:1 e-3 - s (O111 Subsaibed and sworn to before me this day of Ali Amalie, St. Thomas
eux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island in St. Thomas, U. S. Virgin Islands. As part of this project, Epstein contracted with Molyneux to design the interior and exterior of a separate building on Little Saint James Island k
such further relief as this Court deems appropriate. PLAINTFFS DEMAND A TRIAL BY JURY ON ISSUES TRIABLE BY JURY Respectfully submitted, HODGE AND FRANCOIS Dated: July , 2010 By: Denise Francois V.I. Bar Association #285 1340 Taameberg St. Tel. 1~ Fax. Email: Attorneys for Jeffrey Epstein and L
Entities connected to both U.S. Virgin Islands and FRANCOIS

Jeffrey Epstein
PERSONDarren Indyke
PERSON
United States
LOCATION
New York
LOCATION
George W. Bush
PERSON
St Thomas
LOCATIONMaria Farmer
PERSON
Prince Charles
PERSON
New York State
LOCATION
John F. Kennedy
PERSON
Charlotte Amalie
LOCATION
Scarlett Johansson
PERSONthe State of New York
LOCATION
Condoleezza Rice
PERSON
St. John
LOCATION
Saint James
LOCATIONL.S.J.
ORGANIZATION
Delta Air Lines
ORGANIZATION
Phoenix
LOCATION
American Airlines
ORGANIZATION