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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
er specifications and designs provided by Studio and myself or (b) the combination of high temperatures and high humidity levels inherent in Little Saint James' tropical climate, on the one hand, and efforts to maintain cooler air temperatures in the interior space at the Office Pavilion where the Library Ca
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 Molyneux Studio, Ltd., which is incorporated
et forth herein. 2. I am the owner and president of 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
er specifications and designs provided by Studio and myself or (b) the combination of high temperatures and high humidity levels inherent in Little Saint James' tropical climate, on the one hand, and efforts to maintain cooler air temperatures in the interior space at the Office Pavilion where the Library Ca
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
tead a result of either (a) improper specifications and designs provided by Studio and myself or (b) the high temperature levels inherent in Little Saint James' tropical climate, on the one hand. and efforts to maintain cooler air temperatures in the interior space at the Office Pavilion where the Library C
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
er specifications and designs provided by Studio and myself or (b) the combination of high temperatures and high humidity levels inherent in Little Saint James' tropical climate, on the one hand, and efforts to maintain cooler air temperatures in the interior space at the Office Pavilion where the Library Ca
Entities connected to both the State of New York and Saint James'

Jeffrey Epstein
PERSON
New York
LOCATIONFancelli
PERSONthe "Library Cabinetry
ORGANIZATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONStudio and Fancelli
ORGANIZATION
Little Saint James Island
LOCATIONEl Escorial
LOCATIONFancelli Panelling, Inc.
ORGANIZATIONStudio's
ORGANIZATION