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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
ign, color and finish of the proposed Library Cabinetry. Mr. Epstein and I later EFTA00722277 Affidavit of Juan Pablo Molyneux Epstein et al. vs. Fancelli Panelling, Inc. agreed to certain refinements to that design which required that the columns and cornices included in the general design be intricately carved with
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
ign, color and finish of the proposed Library Cabinetry. Mr. Epstein and I later EFTA00589459 Affidavit of Juan Pablo Molyneux Epstein et al. vs. Fancelli Panelling, Inc. agreed to certain refinements to that design which required that the columns and cornices included in the general design be intricately carved with
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
ch Fancelli held itself out as being able to provide; 3 PLAINTIFFS' EXHIBIT 12 EFTA00309235 Affidavit of Juan Pablo Molyneux Epstein et at vs. Fancelli Panelling, Inc. E. Contrary to Fancelli's agreement with Studio, the fabrication and installation of the sliding panels at the windows of the library are incomple
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
sh of the proposed Library Cabinetry. Mr. Epstein and I later EFTA_R1_0 1467544 EFTA02407959 Affidavit of Juan Pablo Molyneux Epstein et al. vs. Fancelli Panelling, Inc. agreed to certain refinements to that design which required that the columns and cornices included in the general design be intricately carved with
Entities connected to both the State of New York and Fancelli Panelling, Inc.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
New York
LOCATIONFancelli
PERSONJ.P. Molyneux Studio, Ltd.
ORGANIZATIONthe "Library Cabinetry
ORGANIZATIONSaint James'
PERSON
Little Saint James Island
LOCATIONEl Escorial
LOCATIONStudio and Fancelli
ORGANIZATIONthe Superior Court
ORGANIZATIONStudio's
ORGANIZATIONMOORE DODSON & RUSSELL
ORGANIZATIONU. S. Mail
LOCATIONFRANCOIS
LOCATIONJean Pierre Fancelli
PERSON
Falwell
PERSONTreston E. Moore
PERSON