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fenses in the action and of the legal issues in the case: In 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
o 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. Molyneux also presented Epstein with Molyneux's own 1 EFTA00725567 Defendants' Discovery Memorandum J.P. Molyneur Studio, Ltd. vs. Ep
d shall not be admissible for any purposes in any litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneux Studio, Ltd., among others. Please be advised that nothing provided by this letter is intended or should be construed as a waiver by my clients of any rig
ame, frustrating every attempt by Mr. Epstein to achieve the required result The cabinetry was to be an exact copy of cabinetry from the library in El Escorial, the historic residence of the King of Spain. More than two years ago, when Mr. Molyneux met with Mr. Epstein in Paris to view a proposed sample of
ntacts with the Territory: That Plaintiffs learned of Fancelli after they engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
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
Entities connected to both J.P. Molyneux Studio and El Escorial

Jeffrey Epstein
PERSONL.S.J.
ORGANIZATIONJuan Pablo Molyneux
PERSONFancelli
PERSONthe State of New York
LOCATION
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSONthe "Library Cabinetry
ORGANIZATIONJ.P. Molyneux Studio, Ltd.
ORGANIZATION
New York
LOCATIONthe Office Pavilion
ORGANIZATIONDesign Services
ORGANIZATIONV.I. Bar Association
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATIONJames Island
LOCATION
Little St.
LOCATIONSt. John District
LOCATION