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TATE OF NEW YORK ) ss: COUNTY OF 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
orth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agre
nd 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 incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epste
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
nd 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 incorporated and maintains its principal place of business in the State of New York (-Studio"). 3. In 2005, Jeffrey Epstein ("Epstein")
TATE OF NEW YORK ) ss: COUNTY OF 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
orth herein. 2. I am the owner and president of J.P. Molyneux Studio, Ltd., which is incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstein") and I, and our respective companies, L.S.J., LLC ("LSJ") and Studio, entered into an agree
nd 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 incorporated and maintains its principal place of business in the State of New York ("Studio"). 3. In 2005, Mr. Jeffrey Epstein ("Epstei
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
Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by and throu
arising out of the Disputes or the Lawsuit 10 EFTA00585555 18. 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
THIS SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is entered into as 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"). WHEREAS, disputes have arisen between Molyneux a
arising out of the Disputes or the Lawsuit 10 EFTA00586562 18. 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
THIS SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is entered into as 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"). WHEREAS, disputes have arisen between Molyneux a
Entities connected to both the State of New York and J.P. Molyneux Studio, Ltd.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
New York City
LOCATION
U.S. Virgin Islands
LOCATION
Prince Charles
PERSON
Russell Simmons
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSON
St. John
LOCATIONV.I.C.
ORGANIZATIONJay Goldberg
PERSONL.S.J.
ORGANIZATIONStudio
PERSONSuperior Court
ORGANIZATIONJ.P. Molyneux Studio
PERSONthe "Library Cabinetry
ORGANIZATIONJean Pierre Fancelli
PERSONDivision of St. Thomas
ORGANIZATIONthe Superior Court of the Virgin Islands
ORGANIZATION