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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
ntacts with the Territory: That Plaintiffs learned of Fancelli after they engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
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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
NQUIRY In their First Amended Complaint, it is alleged "[i]n 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
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by their attorney Rosh D. Alger, herein allege: I. Plaintiff, J.P. Molyneux Studio, Ltd. is a corporation organized and existing under the laws of the State of New York and maintains its principle place of business within the State of New York. 2. Plaintiff Juan Pablo Molyneux at all times hereinafter mentioned was
Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant, Jeffrey Epstein, by their attorney Rosh D. Alger, herein allege: I. Plaintiff, J.P. Molyneux Studio, Ltd. is a corporation organized and existing under the laws of the State of New York and maintains its principle place of business within the Stat
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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
FOR OFFICE DESIGN SERVICES ("Office Design 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"); (collectively the "Parties"). NOW, THEREF
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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
FOR OFFICE DESIGN SERVICES ("Office Design 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"); (collectively the "Parties"). NOW, THEREF
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Mutual Connections (37)
Entities connected to both the State of New York and J.P. Molyneux Studio
Jeffrey Epstein
PERSON472 w/ the·20 w/ J.P.
DI
Darren Indyke
PERSON130 w/ the·6 w/ J.P.
New York
LOCATION93 w/ the·2 w/ J.P.
U.S. Virgin Islands
LOCATION62 w/ the·7 w/ J.P.
Prince Charles
PERSON24 w/ the·2 w/ J.P.
JM
Juan Pablo Molyneux
PERSON12 w/ the·9 w/ J.P.
Russell Simmons
PERSON17 w/ the·2 w/ J.P.
FA
Fancelli
PERSON10 w/ the·6 w/ J.P.
L.S.J.
ORGANIZATION7 w/ the·9 w/ J.P.
V.I.C.
ORGANIZATION12 w/ the·2 w/ J.P.
DF
Denise Francois
PERSON3 w/ the·9 w/ J.P.
JG
Jay Goldberg
PERSON8 w/ the·4 w/ J.P.
Superior Court
ORGANIZATION6 w/ the·5 w/ J.P.
TM
Treston E. Moore
PERSON2 w/ the·8 w/ J.P.
J.P. Molyneux Studio, Ltd.
ORGANIZATION6 w/ the·4 w/ J.P.
Royal Dane
ORGANIZATION5 w/ the·4 w/ J.P.
ST
Studio
PERSON7 w/ the·2 w/ J.P.
the Superior Court
ORGANIZATION5 w/ the·3 w/ J.P.
MOORE DODSON & RUSSELL
ORGANIZATION3 w/ the·5 w/ J.P.
the "Library Cabinetry
ORGANIZATION5 w/ the·2 w/ J.P.