The filing comes from a major civil action in the Southern District of New York brought by six Jane Doe plaintiffs, each suing individually and on behalf of others similarly situated, against a wide array of defendants tied to the U.S. Virgin Islands government. The defendants include the Government of the USVI, former governors, senators, the First Lady, the Attorney General, congressional delegate Stacey Plaskett, and up to 100 unnamed individuals. The lawsuit is part of the broader litigation concerning the role USVI officials allegedly played in enabling, protecting, or benefiting from Jeffrey Epstein’s operations in the territory. This particular document is a memorandum of law submitted by the plaintiffs’ attorneys at Merson Law, PLLC, and it signals that the plaintiffs are actively expanding and refining their claims as new information continues to surface.

Specifically, the plaintiffs are asking the court for permission to amend their complaint under Federal Rule of Civil Procedure 15(a)(3) and to obtain targeted discovery related to jurisdiction and venue. In short, they are arguing that additional facts and defendants need to be formally added to the record and that limited discovery is necessary to establish why the SDNY is the appropriate forum for the case. The motion reflects the plaintiffs’ position that the alleged misconduct by USVI officials is broader and more interconnected than originally understood and that formal discovery will reveal further evidence of systemic failures and complicity. By seeking leave to amend and pushing for early jurisdictional discovery, the plaintiffs are attempting to ensure that the case proceeds on its full factual footing rather than being constrained by procedural defenses raised by the USVI and individual defendants.



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source:


gov.uscourts.nysd.610915.94.1.pdf