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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
abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t
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
abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t
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
abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (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 al
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
abinetry, entry doors, bookcases, bookshelves, columns, cornices, wood paneling and sliding window shutters, for the library in the Office Pavilion (the "Library Cabinetry"). My design for the library of the Office Pavilion, as agreed to by Mr. Epstein, required that the Library Cabinetry was to be a reproduction of t
ddress in the United States Virgin Islands. 3. Upon information and belief, Fancelli Paneling Inc. ("Fancelli") is a corporation, incorporated in the State of New York, which is engaged in the business of restoration and reproduction of antique wood panels and cabinetry in the United States, Canada and Europe. Fan
on. 5,6. Molynewc's services included the design, as well as the delivery and installation, of cabinetry, bookshelves, columns, and wood paneling (the "Library Cabinetry") for the library in the Office Pavilion. Molyneux's design for the library of the Office Pavilion, as agreed to by Epstein, required that the Libr
Entities connected to both the State of New York and the "Library Cabinetry

Jeffrey Epstein
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATIONFancelli
PERSONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONEl Escorial
LOCATIONL.S.J.
ORGANIZATIONSaint James'
PERSONStudio and Fancelli
ORGANIZATIONFancelli Panelling, Inc.
ORGANIZATION
Little Saint James Island
LOCATIONJ.P. Molyneux Studio
PERSONMolyneux Studio, Ltd.
ORGANIZATIONStudio's
ORGANIZATION
Little St.
LOCATIONJames Island
LOCATIONFRANCOIS
LOCATIONFancelli Paneling, Inc.'s
ORGANIZATION