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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
to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es
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
to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es
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
on (the "Library Cabinetry"). My design concept for the library of the Office Pavilion, as agreed to by Mr. Epstein, was inspired by the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of the concept of the library at El Escorial
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
to be a reproduction of the design, color, finish and proportions of the antique cabinetry, bookshelves, columns and wood paneling of the library at El Escorial in Spain. I also provided to Mr. Epstein my own drawing of the proposed Library Cabinetry. On the basis of both photographs of the library at El Es
Entities connected to both the State of New York and El Escorial

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Marc Rich
PERSONFancelli
PERSONJuan Pablo Molyneux
PERSONthe "Library Cabinetry
ORGANIZATIONL.S.J.
ORGANIZATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONFancelli Panelling, Inc.
ORGANIZATIONStudio and Fancelli
ORGANIZATIONJ.P. Molyneux Studio
PERSONSaint James'
PERSON
Little Saint James Island
LOCATIONMolyneux Studio, Ltd.
ORGANIZATIONStudio's
ORGANIZATIONthe Office Pavilion
ORGANIZATION
Little St.
LOCATIONJames Island
LOCATION