Case: 3:10-cv-00034-CVG-RM Document #: 18 Filed: 08/25/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, Plaintiffs, ) -against- Jeffrey Epstein and L.S.J., LLC, Defendants. ) DISTRICT COURT OF THE VIRGIN ISLANDS ) ) ss: DIVISION OF ST. THOMAS AND ST. CROIX ) AFFIDAVIT OF ROSH D. ALGER IN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS THE AMENDED COMPLAINT Case No. 3:10-cv-00034 ROSH ALGER, attorney for Plaintiffs, being duly sworn, deposes and says: I. It is respectfully submitted that should this Court grant this motion to dismiss there is sufficient merit to this action, as will be discussed below, to warrant this Court granting leave to file and serve a Second Amended Complaint pursuant to FRCP Rule 15(a)(2). 2. Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. Plaintiff J.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of New York. Defendant Jeffrey Epstein is a citizen of the Territory of the U.S. Virgin Islands. Upon information and belief, the remaining Defendant, L.S.J., LLC, is organized in the EFTA00731227