Epstein Secrets

orities should be denied in its entirety. Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), Ashcroft v. !Oat 556 U.S. , 129 S. Ct. 1937 (2009), Fowler v. UPMC Shadyside, 578 F.3d 203, 210- 211 (3r° Cir. 2009) (quoting %bal. 129 S.O. at 1949-50), Sheridan v. NGK Metals Corp., 609 F. 3d 239, 262 n. 2

n. Shipping, 549 U.S. 421 at 430 (2007). Defendant's forum non conveniens argument is based upon the false premise that Plaintiffs are residents of the State of New York when the FAC specifically alleges that Plaintiff Jeffrey Epstein is a resident of the Virgin Islands and that L.S.I., LLC maintains its principal a

EW YORK ) ss: COUNTY OF New YAK AFFIDAVIT OF JUAN PABLO MOLYNEUX JUAN PABLO MOLYNEUX, after being duly sworn, deposes and says: 1. I reside in the State of New York, and I have personal knowledge of the matters set forth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorpora

tion 6(a) and Section 6(b) above, the closing shall be conducted by the parties via conference call (the "Closing Conference Call") with Daugherty, Fowler, Peregrin, Haught & Jenson ("FAA Counsel") and the Escrow Agent participating in the call. Seller shall pay the entire cost of FAA Counsel. (a) A

transaction. No assignment shall relieve the assignor of any of its obligations under this Proposal. This Proposal shall be governed by the laws of the State of New York without regard to conflicts of law principles other than Section 5-1401 and Section 5-1402 of the New York General Obligations Law. Each party here

tion 6(a) and Section 6(b) above, the closing shall be conducted by the parties via conference call (the "Closing Conference Call") with Daugherty, Fowler, Peregrin, Haught & Jenson ("FAA Counsel") and the Escrow Agent participating in the call. Seller shall pay the entire cost of FAA Counsel. (a) A

transaction. No assignment shall relieve the assignor of any of its obligations under this Proposal. This Proposal shall be governed by the laws of the State of New York without regard to conflicts of law principles other than Section 5-1401 and Section 5-1402 of the New York General Obligations Law. Each party here