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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
Virgin Islands Has Local Interest in the Controversy. Jeffery Epstein is a resident of the United States Virgin Islands. His wholly owned company, L.S.J., LLC, maintains its principal address in the Virgin Islands and owns the real estate which, as stated above, is the locus of the controversy in thi
ascertain and that such amount does not represent a penalty. 14. This Agreement shall be governed by and construed in accordance with the laws of the State of New York applicable to agreements entered into entirely within the State of New York, without regard to the principles of New York law regarding conflicts o
s of this day of November, 2010, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, in exchange for One Dollar ($1.00) and other valuable
ddress in the United States Virgin Islands. 3. Upon information and belief, Fancelli Paneling Inc. ("Fancelli") is a corporation, incorporated in the State of New York, which is engaged in the business of restoration and reproduction of antique wood panels and cabinetry in the United States, Canada and Europe. Fan
., state the following: 1. The Plaintiff, Jeffrey Epstein ("Epstein"), is a resident of the United States Virgin Islands and is the sole member of L.S.J., LLC. 2. The Plaintiff, L.S.J., LLC ("LSJ"), is a limited liability company organized under the laws of Delaware, is the owner of Little St. James
ther Party of any other provision of this Agreement, the non-breaching Party shall have such rights and remedies as are provided for by the laws of the State of New York in accordance with Paragraph 15 of this Agreement. 14. If any submission, arbitration or court proceeding relating thereto is brought by any Party
cember, 2010 (the "Effective Date"), by and among Juan Pablo Molyneux ("JP"),.. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, in exchange for good and valuable consideration, inclu
sel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. 2. 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 Ne
into this 15th day of May, 2009, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio', and together with JP, "Molyneux,") L.S.J., LLC ("LSI") and JeffLeLEpstein ("Epstein"-)r _Each-of-the-partter hereto ((the 'Pardee), intending to be bound hereby, hereby agrees as follows;
collectively, the "Sexual Abuse Claims"). To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal courts of the State of New York, where claimants assert some of the complained-of conduct occurred, and which recently amended its statute of limitations to permit such claims. The
. A deed recorded with the Virgin Islands Recorder of Deeds on December 30, 2011 reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus, Inc. for "TEN DOLLARS ($10.00) and other good and valuable consideration." The quitclaim deed lists EFTA00074775 GVI v. Estate
ascertain and that such amount does not represent a penalty. 14. This Agreement shall be governed by and construed in accordance with the laws of the State of New York applicable to agreements entered into entirely within the State of New York, without regard to the principles of New York law regarding conflicts o
s of this day of November, 2010, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio", and together with JP, "Molyneux,") L.S.J., LLC ("LSJ") and Jeffrey Epstein ("Epstein"); (collectively the "Parties"). NOW, THEREFORE, in exchange for One Dollar ($1.00) and other valuable
Entities connected to both the State of New York and L.S.J.

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATIONDarren Indyke
PERSON
Federal Reserve
ORGANIZATION
George W. Bush
PERSON
New York
LOCATION
New York City
LOCATION
U.S. Virgin Islands
LOCATION
Deutsche Bank
ORGANIZATIONthe Southern District
LOCATION
Samantha Power
PERSONJane Doe
PERSON
Financial Trust Company
ORGANIZATION
the United States District Court
ORGANIZATION
Richard Kahn
PERSONSouthern Trust Company
ORGANIZATION
Palm Beach
LOCATIONMaria Farmer
PERSON