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residing in 2005) and Molyneux (New York), then an agreement between Molyneux and Fancelli (New York). It is respectfully submitted that the law of the State of New York will be operative throughout this litigation on matters sounding in contract and, to a lessor extent, derivative matters of negligence as well. Alt
hat agreement and the reasonable expectations .of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
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 Yo
n of the Design Services Agreement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman, undertook to and did perform the Exhibit B Services, with the exception of the restaining and refinishing of the wood cabinetry. On January 26 and 27, 2010, Plaintiffs travelled to Little Saint Jame
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
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
nsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. PlaintiffJuan Pablo Molyneux is a citizen of the State of New York. 2. PlaintiffJ.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of New
that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and fa
Entities connected to both the State of New York and the Exhibit B Services

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Russell Simmons
PERSONJuan Pablo Molyneux
PERSONFancelli
PERSON
Patty
PERSONJay Goldberg
PERSON
Saint James
LOCATIONStudio
PERSONRoyal Dane
ORGANIZATIONRosh D. Alger Esquire
PERSONMolyneux Studio, Ltd.
ORGANIZATIONthe Office Pavilion
ORGANIZATIONMOORE DODSON & RUSSELL
ORGANIZATIONDenise Francois
PERSONVI Bar No
ORGANIZATIONthe Territory of the
LOCATIONAdjudging
LOCATION