Epstein Secrets

Plaintifft• Opposition to Defendant's Motion to Dismiss Epstein 0 al vs. Fanelli Paneling. Inc. Case No. ST-10-CV-443 upon arrival of the goods in Ncw York and keep same in storage while they awaited further shipment to Africa. Unfortunately, after the goods were delivered to Major Van Lines' depot, th

NY, NY 10013 19th d f , 010 212.925.1220 TARY I'UBLI RAAINTRIF,c'S EXHIBIT 7 NOTARY PUBLIC • STATE OF NEW YORK NO. 01R16109719 OUALiF!ECI IN NEW YORK COUNTY ‘.C, MISSION EXPIRES MAY 17, 2012 EFTA00309219 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND St JOHN JEFFREY EPSTEIN a

t contacts the defendant has with the forum, measured against the burden of the defendant in defending in that forum. Godfrey, 18 V.I. at 68-69 and World-Wide Volkswagen Corp. v Woodson, 444 U.S. 286 292(1980). 12 EFTA00309192 Plaintiffs' Opposition to Defendant's Motion to Dismiss Epstein el al. it Fanelli Paneling.

ditionally, general jurisdic- tion could be appropriate for the SAAR Network entities having offices in Virgi- nia. Id, 1227. Accordingly, the SAAR Network's motion to dismiss is denied without prejudice. The parties are to en- gage in jurisdictional discovery to deter- mine which of the Network's entit

ditional notions of fair play and substantial justice." Intl Shoe Co v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945); see also World-Wide Volkswagen Corp. v. Wood- son, 444 U.S. 286, 292, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). The minimum con- tacts requirement is also known as "fair warning," such tha

exception of FSIA; 7 a, survivors failed to make prima facie showing necessary to establish person- al jurisdiction over Princes and others under New York’s long-arm statute; (8 nai modified due process standard appro- priate for mass torts would not be applied to question of personal juris- diction;

traditional notions of fair play and substantial justice.” Intl Shoe Co. v. Washington, 326 U.S. 310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945); see also World-Wide Volkswagen Corp. v. Wood- son, 444 U.S. 286, 292, 100 S.Ct. 559, 62 L.Ed.2d 490 (1980). The minimum con- tacts requirement is also known as “fair warning,” such that