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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
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; EFTA00310026 Case: 3:10-cv-0003
sel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. 2. Plaintiff J.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of Ne
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; 4 EFTA00308305 Case: 3:10-cv-0
nsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. PlaintiffJuan Pablo Molyneux is a citizen of the State of New York. 2. PlaintiffJ.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of New
rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; 4 EFTA00299559 Case: 3:10-cv-0
Entities connected to both the State of New York and Adjudging

Jeffrey Epstein
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATIONJuan Pablo Molyneux
PERSONFancelli
PERSON
Patty
PERSONJay Goldberg
PERSONStudio
PERSON
Saint James
LOCATIONRoyal Dane
ORGANIZATIONthe Exhibit B Services
ORGANIZATIONRosh D. Alger Esquire
PERSONthe Office Pavilion
ORGANIZATIONVI Bar No
ORGANIZATIONthe Territory of the
LOCATIONIncluding
ORGANIZATIONSt James Island
LOCATIONthe Escorial Library
ORGANIZATIONDenise M. Francois
PERSONRoth D. Alger
PERSON