El IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. III IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. DIVISION 2 CIVIL IN DISTRICTS • OTHER CIVIL ACTION SUMMONS (b) Form for Personal Service on a Natural Person CASE NUMBER 14021348CA01 PLAINTIFF(S) JEAN-LUC BRUNEL VS. DEFENDANT(S) JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A YI.ORG CLOCK IN THE STATE OF FLORIDA:TO EACH SHERIFF OF THE STATE, YOU ARE COMMANDED to serve this Summons and a copy of the Cotr4taint this lawsuit on defendant: in To Defendant(s): JEFFREY EPSTEIN Address: -1.,*,---,; •Ef-i:e • I-f-2- -(Jble,4- *(40,,,t4t-f-AIP' 358 El Brilio Way Palm Beach, FL 33480-4730 .1"cl$F1..31 IMPORTANT A lawsuit has been tiled against you. You have 20 calendar days after this summons is served on you to file a written response to attached complaint with the derk of this courL A phone call will not protect you.Yrxr written response, including the cose number given above and the names of the parties must be filed if you want the CODA to hear your side of the C.8541. If you de not filer your resporM time, you may lose the case, and your wages, money and properly may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney, you may call an attorney reierral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response with the Clerk of the Court you must mail or take a copy of your written response to the "P(aintiff/Plaintiffs Attorney' named below. The central location of the Clerk's office at the Dade County Courthouse. The address for the courthouse, and branch locations are listed below for your comenience: DADE COUNTY COURT LOCATIONS the on also is EiDade County Couitbouss (06) I Joseph Caleb Cantle- (20) 0 Notth Dade Justice Cordes (23) Room 133 Room 103 Room 100 73 Watt Hagler Street 5400 NW 22 Avenue 15555 Biscayne BM/. Miami, Florida 33130 Warm, Florida 33142 North allarri Beach. Flottda 33160 ElMimi Beach District Court (24) In Corti Gabtas District Court (25) II South Dade Justice Center (26) Room 200 Room 100 Room 1200 1130 Washington Amosie 3100 Pono: De Lem BIM 10710 SW 211 Stnied Miami Beach, Florida 33133 Coral Gables, Floricia 23134 WA* Honda 331/10 II Hialeah District (21) Room 100 11 East 61h areal Hialeah. Florida 33010 SERVICE Plaintiff/Plaintiff Attorney JOE TITONE Florida Bar No. 203882 Address: 621 S.E. 5TH STREET, POMPANO BEACH, FL 33060 HARVEY RUVIN CLERK OF COURTS VIVRA Sikilumt: ir BY: , DATE ON: 1E6 0 0 2015 DEPUTY CLERK AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order participate in this proceeding, you are entitled, at no cost to you, to the provision certain assistance. Please contact the Eleventh Judicial Circuit Court's ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification time before the scheduled appearance is less than 7 days; if you are hearing or impaired, call 711." to of if the voice _________ CLIC/CT. 070 Rev. 11111 Cleric's limb address: meat. D EN LA CORTE DE CIRCUIT° DEL UNDECIMO CIRCUIT° JUDICIAL EN Y PARA EL CONDADO DE MIAMI-DADE, LA FLORIDA. 0 EN EL TRIBUNAL DEL CONDADO EN Y PARA EL CONDADO MIAMI-DADE, LA FLORIDA. DIVISION DI CIVIL L _ OTRA EMPLAZAMIENTO DE ACCION CIVIL (b) NOTIFICACION PERSONAL A PERSONA NATURAL NUMERO DE CASO DEMANDANTE(S) VS. DEMANDADO(S) HORA A Demandado(s): Direccion: listed ha sido demanded° legalmente. Tbene 20 dias, escrito, y presentarla ante este tribunal. Una LIamada presenter SU respuesta por esaito, induyendo el numero tiempo, pudiese peeler el caso pordria ser despojado Existen otros regtisitos legates. Si lo desea. poade una de (as oficinas de asistencia legal (Legal Aid Is guia telefonica. SI desea responder a la dementia por su cueeta, al o entregar en la mane una copia de SU respuesta a Demandante) y presenter su contestadon a la domande edificio de la Code del Candado de Dade. La direccion LOCAL1DAD CI Dade County Courthouse (05) 0 Joaeph Caleb Room 133 Roue 103 73 Weal Flagler Street 540 NW 22 hitiorni, Rcrioa 3313D Miami, Florida 1:1 kbarrd Eleach Cestrict Court (24) 0 c.aki oatkii Room 200 Room 100 1130 Washington Avenue 3100 Ponce MAarn1 Beath, Florida 33139 Cm( Galslea. IMPORTANTE contester la demanda adj crinsidere su defense, Sl usted no contests la denanda sin previo aviso del a un abogado, puede Referral Service) que aparIcen debera usted envier ofir (Demandante o Ahmed° la Mina del Secretario elta para su convenienci2: El Walsall Dtatrict (21) Room 100 11 Bost 6th Street Hialeah, Hondo 33010 nia, por debe a tribunal. Ikamar a en correo del en el cordados a partir del recibo de este notification, para leiefonica no lo protegera. Si usted desea que el tribunal del caso y los noinbres de Las partes irderesadas. de sus ingresos y propiedades, o privado de sus denachos, usted consulter a un abogado inmediatamente. Si no conoce Office) o tin servicio de referenda de abogados (Attorney misrno liampo en que presents SU respuesta ante el tribunal, la persona denominada at)* como 'Plaintiff/Plaintiffs Attorney" al Secretario del Juzgado. La tibial:ion central de de ta Code, y de (as sucursales aparecen en la Lists siguiente DE LOS 71IBUNALES DEL CONDADO DE DADE Career (20) 0 kWh Dade Judio5 Clatter (23) Room 100 Avenue 15555 Biscayne Elhod. 33142 North Marra Beach, Floeda 33150 District Cowl as 0 South Dade Justine Center (25) Room 1200 De Lem PM. 10710 SW 211 Street Fi011112 33134 Mama, Florida 331E19 Dernandante c Abogado del Demandante Numen3 del Colegio de Abogados: Direccion: EL ESTADO DE LA FLORIDA: A cada alguacil del Estado: Se le ordena que hagen entrega de esta nolificacion y u copia de la demanda en este pied° at tlemandatio(s) mencionada arriba. la HARVEY RUVIN Secreted° del Tribunal del Condado POR: FECHA GornoSecretario Adjunto Ley para Estadounidenses con Incapacidades "Si usted es una persona minusvalida gue necesita bacer arreglos para poder participar en este proceso, usted tiene derecho, sin gasto alguno, a que se le provea cierta apda. Por favor pong_ase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial uhicado en el Lawson E. Thomas Courthouse Center, 175 NW 1st Ave. 2702, Miami Fl 33128, Telefonos (305)349-7175; TDD (305) 349-7174, Fax (305) 349-7355 por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales; inmediatamente despues de recibir esta notificacion si el tiempo antes comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la voz, llame al 711." Sala o de la CLK/CT. 070 Rev 11111 Clerk'es web cellintss: Ninny. U AU TRIBUNAL DU ONZIEME ARRONDISSEMENT JUDICIARE DANS ET POUR MIAMI-DADE, FLORIDE. 0 AU TRIBUNAL DE JUGEMENT Er POUR LE DEPARTENT DE MIAMI-DADE, FLORI DE. DIVISION CI CIVILE D AUTRE CONVOCARION (b) LIVRAI ON PERSONNELLE Cr ACTION CIVILE A UNE PERSONNE NUMERO DE CAS PLAINTE(S) VS. CONTRE ACCUSE(S) HEURE IN A (AUX) ACCUSE(S): ADRESSE: Des poursuites judiciaires ont ete enterprises contra citation pour deposer use response mite a La plainte protegee. Vous etas obliges de deposer votre response nommees ici, si VDUS souhailez qua ,:a tribunal entende risquez de perdre is cause sins' que vote sataire, tribunal. II y a d'autres obligations juridiques at vous vous pourriez telephoner a tin service reference cfavocats Si votts choisissez de deposer VOUS-Mellie UM reponse expedier une copte de votre reponse ecrite au •PlairtifiPtairdirs reponse avec le Grafter du Tribunal. L'adresse l'adresse des succursales sort dans ci-dessous pour 0 Dade County Courthouse (05) 0 Joseph Czech Room 133 Room 103 73 Weal Flaglet Street 5400 NW 22 Miami, Florida 33130 Warr& Ficrida El ktierni Beech Dtstrict Ccurt (24) 0 Corot Gables Room 200 Room 100 1130 Washington AVellie 3100 Ponce SAWN Beach. Florida 33139 CCIAI Gebtee, IMPORTANT la data de rassignation de est insoffisant pour ci-dessus at du nom des ecrite dans le relai requiS. suite, aucun preavis ulterle vous no connaissez pas d'• rannuaire de telephones). cette formate, faire parvCnir ci-dessous at emegistrei L'adresse du trib 0 Htelesh District (21) Room 100 11 East 6th Street Hialeah, Flodde 33010 cede vous 3arties VOUS ur du vocal, ou votre nat,el VOUS. Vous ci-jointe ecrite, vote votre argent, pouvez requerir ou a ecrite, centrale du wire convenance avez 20 jours consecutifs a partir a de aupres de 03 Irthurtal. Ull SkT1010 coup de telephone ac mention du nurnero de dossier muse. Si vous no deposez pas aotre reponse at vos biens peuvent etre saisIs par La les services immedlats d'un avocet. Si tin bureau dessistance juridique (frgurard a it VOUS faudea egaternent, en memo temps qua Attorney (PlaignaM ou a son avocet) nomrne bureau du Craftier est le Dade County Courthouse. DES IRIBLINAUX EN DADE 0 North Dade Justice Center (23) Room 100 15.53 Biscayne Btvd. North Wand Broth, Florida 33160 (25) 0 South Dade .histice Center (26) Room 1200 10710 SW 211 Steel Wane, Ronde 33189 ADRESSES Cotter (20) Avenue 33142 District Court Be tem Stmt. Florida 33134 Plainte/Avocat du Plainte Numero de barreau de la Floride: Adresse: LTAT DE LA FLORIDE A chaque sherff de retat vous etes oblige de presenter cette citation et une photocpie de la plainte ce document sur rarnuse (e) ci-desus. ie HARVEY RUVIN Greffier de Tribunal ' PAR: DATE ON: OOMVE GREFFER Af1101NE .. ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE l' ADA "Si vous etes une personne handic,apee qui a besoin d'accommodement pour pouvoir participer a cette procedure, vous avez le droit, sans aucun coot, d'avoir de l'aide a disposition. S'il vous plait contacter le Coordinateur de l'ADA du Tribunal de l'OnYieme Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW 1.3t Ave. Suite Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 moms 7 jours avant la date de comparution au tribunal, oubien immediatement avoir recu cet avis si la date avant la comparution est moms de 7 jours; si vous avez incapacite pour entendre ou parler, appelez le 711." votre 2702, au apres une CLKJCT. 070 Rev. 11/11 Cient's eth address: anew erk.com 0 NAN TRIBUNAL ONZYEM AWONDISMAN JIDISYE NAN E POU MIAMI-DADE COUNTY, FLORIDA. 0 NAN TRIBINAL E POU TRIBINAL NAN MIAMI-DADE COUNTY, FLORIDA. DIVIZYON El SIV1L 0 LOT KONVOKASYON POU KA SIVIL (b) DELIVRE PERSONELMAN BAY YON DAMN NIMEWO KA PLENTIF(S) VS. KONT AKIZE(S) LE AKIZE: ADRES: Yo entre yon aksyon kont oumeum. Ou genyen 20 jou grefie tribunal-sa, yon reponce pa ecri attache avec plent4a. ecrifo ou mete numero ka-a ki sou tet pagela avec nom position-0u cou ka-a. Si ou pa enregistre reponce-ou ou capab pedu l'agen ou ak byen ou. Genyen lot demande. avoka, ou ka rele sevis id rekomande evoke, ou biro ede Si ou shoisi voye yon reponce pa ecri oumenm, ou supose pa ecri pou avoka pleyan ou pleyan-yo ke non-li ama-a Tribinal. Adres santrat biwo Sekrete a se Dade County pou ou kaiwenn ye alez: MIRES TRIB1NAL 0 owe ccuity C,osethouse (05) CI Joseph Caleb Center (20) Room 133 Roam 103 73 West Ftagler Street 5400 NW 22 Avenue Warm, Ronda 33130 Ward, Florida 33142 Ell Miami Beech Distri:1 Cool (24) LI ower Saida* Dielnct Court Room 200 Room 100 1130 Washington Avenue 3100 Porto% De Loon 131,41 Mani Bomb, Floada 33135 Coral Gablex Florida 33134 En pou enregistre cevan Se yen repenite si ou vie ke tribunal-la la pa enounce-ou en de suit. Si ou pa !oriel on pote on copi response ki localize nan avek lot tribinal yo nan lis ki CI lilal DtstOot (21) Roam 100 11 Eest 6th Sliest 1-11sioa1i. Rod& 33010 pa kende yen, yen --krete .nba a kalandriye apres ou recevoi sornasyon-an Yon apei pa teleran ka kapab protege-ou. moune-yo ki sou papie-sa oblige ecri a l'heure ou capab pedu ke-a san tribunal Ou ka besoin telefone yon avoka tout legal (ki nun lis liv telefone). en mem Ian poste en mem tan poste et enregistre reponce-la nan tribunal-la Courthouse. Adres tribinal la, ak adres NAN DADE COUNTY El 1-4.111 Dade Justtos Genie/ (23) Room 100 15555 Btscayne Blvd. North tani Reach. Fltrittl 33160 (25) 0 South Dade Justice Center (76) Room 1200 10710 SW 21) Street Welt Ronda 33189 Plainta/Avocat du Plainie Numero de barreau de la Floride: Nimewo manm avoka a. Address: ETA FLORIDA: Pou Chak nan eta a yo odone ou pou bay akize a (yo), non I ekri anwo a, manda sa a ak yon kopi yo pate an pwose sa a. HARVEY RUVIN Sekrete Jenemi Tribinal La BAY: DATE: SEKRETE LWA 1990 POU AMERIKEN KI ENFINI ANONS POU ANIERIKEN KI ENFINI "Si out se yon moun ki enfim e on bezwen akomodasyon pou on patisipe nan pwosei sa a, on gen dwa pou yo ba ou kek ed san on pa gen pou on peye. Silvouple ko 1 takte KowOdinate ADA pou Tribinal Onzyem Distrik Jidisye a nan: Lawson E. To omas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, Fl 33128, Telefen (305 349- 7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan on gen randevo pou on paret nan tribunal la, oubyen imedyatman le on resevwa notifikasyon sa a si o gen mwens ke 7 jou pou ou paret nan tribunal la; si on gen difikilte pou on tande o byen pale, rele 711." CU(/CT. 070 Rev. 11/11 CiefleS web adriress: www.vgp erk.oam Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC Civil Action No.: 14-21348 CA 01 Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. / AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND DAMAGES COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami, LLC, by and through undersigned counsel, and sues Defendants Jeffrey Epstein, Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable relief and defamation, and states as follows: 1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County, Plaintiff Jean-Luc Brunel resides in Dade County, Florida, and Plaintiff MC2 Model & Talent Miami, LLC, has an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. 2. Florida Statute 48.193(1)(a)(1) ("long-arm") authorizes service on both out-of-state Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org). 1 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jean-Luc Brunel is the owner of Plaintiff modeling agency known as "MC2 Model & Talent Miami" ("MC2"). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 5. Defendant Jeffrey Epstein ("Epstein") is a hedge-fund manager with a residence in Palm Beach County, Florida. Defendant has been the subject of significant media coverage due to charges brought against him involving sexual contact with minors. (Composite Exhibit A attached). 6. Plaintiff Brunel and Epstein have known one another since the inception of Plaintiff MC2. 7. Plaintiff Brunel operated his modeling agency, Plaintiff MC2, without incident until Epstein was first charged in Palm Beach County with unlawful sexual contact with a minor in 2006. He was convicted of soliciting prostitution from a minor and sentenced to eighteen months in prison, of which he served thirteen months. He remains a registered sex offender in Florida as of this day. 8. First, after the initial criminal charges against Epstein were filed in Palm Beach County, Plaintiffs were widely implicated in the media as being "linked" to Epstein. These false stories caused both Plaintiffs a tremendous loss of business. 9. Plaintiffs lost multiple contacts and business in the modeling business as a direct result of Epstein's illegal actions. For example, several photographers will not work with MC2 due to the 2 adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking Plaintiffs with those activities; namely, sex trafficking. (Composite Exhibit A). 10. One example of such a photographer was Michael Avedon, who worked with MC2 on photo shoots. Avedon stopped answering Plaintiffs' emails and phone calls after having known Plaintiff for some time. Upon meeting Avedon out one night, Avedon stated to Plaintiff Brunel he had "found out some information" from some friends of his and that he could not associate his name with MC2. 11. This statement by Avedon was no doubt a reference to the alleged and false links between Plaintiffs and Epstein's illegal activities with under-aged girls. This incident clearly illustrates an example of lost business on Plaintiffs' behalf. 12. The second example of a business relationship that was terminated due to Epstein's intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos Model Agency. The owner stated that the model to be placed with MC2 "found some article in Internet, which changed her position and she preferred to be placed with another agency." This was relayed to Plaintiff Brunel by e-mail dated October 15, 2014. This amply demonstrates that Epstein's intentional & illegal activities continue to cost Plaintiffs' business income. (Exhibit B attached). 13. A third example of a lost business relationship can be found in an e-mail dated October 17, 2014 (Exhibit C attached). The director of the 1 Mother Agency, Vladmir Yudashkin, states that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs' will force her into illegal activities. The model bases her fears upon the stories on the intemet falsely implicating Plaintiffs as being involved with illegal activities with young models. This is 3 another example of a false link between Epstein and Plaintiffs, costing Plaintiffs' business income. 14. A fourth example of a lost business relationship can be found in a second e-mail dated October 17, 2014 (Exhibit D attached). Manuela Martinez of Mega Partners, a Brazilian modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs. This reference is clearly to the false allegations online regarding sex trafficking that were based in the false link between Epstein and Plaintiffs. 15. A fifth example of a lost business relationship can be found in an e-mail dated on Plaintiff's behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of Epstein's illegal activities, Plaintiff Brunel was forced to forego (and lose) this business opportunity because he needed to keep a low-profile at this time. 16. A sixth example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail dated December 12, 2014. (Exhibit F attached). Michael Sanka, a talent scout who had worked with Plaintiffs for a number of years, informed Plaintiff Brunel that he cannot sign any new models for Plaintiff Brunel's MC2 agency due to the false sex trafficking allegations online. Sanka goes on to state that Plaintiff Brunel's MC2 agency will not attract any new models if Plaintiff Brunel does not clear up the false allegations. 17. A seventh example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail from Fox Fashion Agency (Exhibit G attached). This e-mail clearly states 4 that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems. However, because of the false internet trafficking links between Plaintiffs and Epstein, Fox states that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up. 18. Before the false links between Plaintiff and Epstein surfaced, Plaintiff Brunel was earning a great deal of revenue from MC2 Miami. 19. The false links between Plaintiffs and Epstein began to surface online in about 2005- 2006. Then, in 2006, Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs then made an investment totaling one-million dollars with Elite Paris, to start a company. 20. Next, Plaintiff Brunel started the company, "E Management", to work with Elite Models in Paris, Plaintiff had to close it almost immediately, because Elite didn't send any models to Plaintiff MC2 for fear of being linked to Epstein. 21. Because the false links between Plaintiffs and Epstein began to gain strength online, Elite Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment of one-million dollars because of this loss of business. 22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar loss. 23. Additionally, a former financial controller of MC2, Maritza Vasquez, stated in a 2012 deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under- age model. (Exhibits HI & H2 -Transcript of Deposition of Maritza Vasquez). 24. Maritza Vasquez was fired from her job at Plaintiff MC2 for embezzling company funds, and had criminal charges filed against her (Composite Exhibit I attached). She was also the source of the false information linking Plaintiffs to sex trafficking in the articles written by Conchita Sarnoff of the website Jezebel (Composite Exhibit A. p.2-7). 5 25. The deposition testimony of Maritza Vasquez referred to above clearly demonstrates that Plaintiff Brunel has clean hands and was never involved in sex trafficking. All of Plaintiffs' damages came solely from Epstein's conduct. 26. Additionally, Plaintiff Brunel has had significant delays in obtaining his visa to come to the U.S. These delays were also the result of the false link between Plaintiffs and Epstein. As a result of these delays, Plaintiffs lost a considerable amount of time & money. International travel is a significant component of Plaintiff Brunel's MC2 modeling business. Plaintiff Brunel has been forced to cancel his latest visa application as a result of the delays. (Exhibit J — Composite Visa Does). 27. As a result of the notoriety and tremendous publicity surrounding Epstein's criminal charges, and the media linkage of Epstein to Plaintiffs regarding illegal activities, Plaintiffs lost a tremendous amount of business and revenue. 28. Plaintiff Brunel's agency MC2 has lost millions of dollars in revenue since the media revealed that Plaintiffs and Epstein were associated. In fact, Plaintiff MC2 was worth millions of dollars; now, due to the illegal actions of Epstein, MC2 is almost worthless. 29. At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the Epstein's illegal activities. 30. As a result of Epstein's illegal activities and his association with Plaintiffs, Plaintiffs continue to lose money and suffer damages to this day. (Exhibit K attached, Jeff Fuller email, 11-12-14). 31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to what it was once worth — money that the Plaintiff Brunel does not have. 6 32. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names never having been cleared from the massive and totally negative media coverage involving Epstein and his illegal activities. Plaintiffs have been, and continue to be, irreparably harmed by these false internet-based links to Epstein. (Exhibits R & S attached). 33. Second, Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Brunel's deposition. 34. As a direct result of Plaintiff Brunel's travels, his deposition was delayed twice. When it was finally scheduled for November 2009, Plaintiff Brunel was in fact available (Exhibit L attached). However, a medical emergency in the family of his attorney further delayed this deposition (Exhibit M attached). It was never rescheduled and he was never deposed. 35. This was a blatant example of obstruction of justice in the criminal case. Epstein was solely responsible for telling Plaintiff Brunel to leave the area. Plaintiff Brunel lost a huge opportunity to clear his name, and that of his agency, Plaintiff MC2. 36. Third, as a result of all of the facts stated above, Plaintiff Brunel was under tremendous psychological pressure throughout this period of time. 37. This psychological pressure resulted in Plaintiff Brunel avoiding business contacts as set forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts during this period of time. 38. Plaintiff Brunel became extremely withdrawn and anxious at this time. 39. Epstein's conduct was the direct cause of Plaintiff Brunel's psychological state. The press was reporting extensively on the lurid details of Epstein's illegal activities with the under- aged girls. 7 40. As stated above, the press reports were erroneously connecting both Plaintiffs to Epstein's illegal activities. (Composite Exhibit A attached). 41. Epstein's illegal activities were outrageous and extreme; they involved receiving massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the girls with a finger or object; or full-intercourse. 42. These activities described above caused Plaintiff Brunel severe emotional distress. In fact, Plaintiff Brunel has recently undergone psychotherapy with a local psychologist, Dr. Royce N. Jalazo, as a result of Epstein's actions and the negative results on his business. (Exhibits N & 0 attached). 43. Plaintiff Brunel is emotionally destroyed as a result of Epstein's actions and the resultant effects on his business. He has been on medications to deal with the effects of this. (Composite Exhibit P — Medical History). 44. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counsel to represent him in this matter, and are obligated to pay counsel a reasonable fee for his services. FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A YI.ORG 45. Defendant Tyler McDonald ("McDonald") is the owner/operator of Yi.Org and also does business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org"). Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service based in Vancouver, British Columbia, Canada. 46. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting websites that contained hyperlinks that contained blatantly false and extremely disparaging information about Plaintiffs. (Exhibit Q attached - hyperlink screenshot). 8 47. These links clearly and falsely associated Plaintiffs with illicit escort services in the state of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or should have known, was false. 48. These links have damaged Plaintiff Brunei's reputation as an owner of a well-established modeling agency with offices in New York and Miami, Plaintiff MC2. 49. These links have also damaged the reputation of both Plaintiffs. 50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss of revenue to Plaintiff MC2, and accordingly, to Plaintiff Brunel. 51. Plaintiff MC2's revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Plaintiffs' reputation and directly caused damages to Plaintiffs. 53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, both names still harmed by the false and negative association with escort services in Florida. 54. Accordingly, Plaintiffs have been severely damaged by information on websites hosted by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 55. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged involvement with escort services in the state of Florida. 56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the names of Plaintiffs with regard to the false and defamatory information disseminated by the 9 websites they hosted. 57. Plaintiffs continue to do business to this day, their names never having been cleared from the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald. 58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and McDonald, and have accordingly retained undersigned counsel to represent him in this matter, and are obligated to pay counsel a reasonable fee for his services. COUNT I — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANT JEFFREY EPSTEIN 59. The allegations contained in paragraphs 1 through 44 above are re-alleged and incorporated herein by reference. 60. Plaintiffs have lost a significant amount of business revenue because of the actions of Defendant Epstein set forth above. 61. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of Defendant Epstein. 62. Accordingly, Plaintiffs seeks to become whole by the payment of damages by Defendant Epstein to compensate him for his losses. WHEREFORE. PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT II — OBSTRUCTION OF JUSTICE — EQUITY - AS TO DEFENDANT JEFFREY EPSTEIN 63. The allegations contained in paragraphs 1 through 44 above are re-alleged and incorporated herein by reference. 10 64. Plaintiff was forced to commit illegal acts by traveling away from the sight of the deposition and during the time period of the deposition. 65. Defendant Epstein attempted to subvert justice and this attempt contributed to the destruction of Plaintiff's business, Plaintiff MC2. Plaintiff Brunel lost substantial time away from his business and incurred expenses in following Epstein's commands. 66. Plaintiffs were substantially damaged as a direct result of Epstein's actions. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT III — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 67. The allegations contained in paragraphs I through 44 above are re-alleged and incorporated herein by reference. 68. Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by engaging in illegal conduct with under-aged girls, which was falsely linked to Plaintiffs. 69. This illegal conduct was extreme and outrageous by any standard. 70. This extreme and outrageous conduct was the direct cause of extreme emotional distress in Plaintiff Brunel. WHEREFORE, PLAINTIFF BRUNEL requests judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate II COUNT IV — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG 71. The allegations contained in paragraphs I through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 72. Plaintiff, through his agency MC2, has lost a significant amount of business revenue because of the actions of Defendants McDonald d/b/a Yi.Org and McDonald set forth above. 73. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of both Defendants. 74. Accordingly, Plaintiffs seek to become whole by the payment of damages by both Defendants to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT V — DEFAMATION AGAINST PLAINTIFFS — AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YLORG 75. The allegations contained in paragraphs 1 through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 76. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published, false statements about Plaintiffs using their domain hosting service. 77. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the statements about Plaintiffs were false. 78. These published statements were read by the internet users who viewed the false statements. 79. Plaintiffs' business reputations were severely damaged as a result. 12 WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT VI — EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A/ YLORG 80. The allegations contained in paragraphs 1 through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 81. Plaintiffs have also suffered a significant loss of their business reputations as a direct result of the actions of Defendants McDonald d/b/a Yi.Org and McDonald. 82. Plaintiffs have no adequate legal remedy to make them whole as a result of the damages suffered in the form of lost business reputations due to the actions of both Defendants. 83. Accordingly, Plaintiffs seeks to restore their business reputations by the payment of damages by both Defendants to compensate them for their loss of reputations. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. Is/ Joe Titone Joe Titone Attorney FL BAR #: 203882 621 S.E. 5th Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) Joetitone708@comcast.net 13 VERIFICATION STATE OF FLORIDA COUNTY OF/f-i/--1-44/ /211.0 JEAN-LUC BRLTNEL, being duly sworn according to law, upon his oath, deposes and says: I have read the foregoing complaint and all the allegations contained therlin. All such allegations are true based upon my personal knowledge, informatio and belief. I (id! JE BRL Sworn and subscribed to before me this / day of4e2z,...,/-r , 2014. PALO VALLAMES Nanny Pal4c - Florkta 1 lir Caren. barn Oc.1 31, an B Coarniala •Eg 211500 4 Scrawl Throw* NSW Navy Mot ps...i.......upeirimpnwepeopmempft NOTARY PUBLIC 6 14 COMPOSITE EXHIBIT A http://www.thedailybeast.com/articles/2010/07/29/jeffrey-epstein-feds-probe-possible-child- trafficking-charge.html Epstein Faces Sex-Traffic Probe The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last week. But it appears his problems may not be over. Now The Daily Beast has learned that: • Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge than the two in his non- prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. • The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein's private jets. Because Epstein's predatory habits stretch back many years and involved dozens of young- looking girls, there may well be more evidence to uncover. Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash settlements in these civil suits agreed not to testify against him or speak publicly about the case. However, new evidence developed by the Department of Justice on other offenses not covered by the agreement, including allegations by additional victims who come forward, could lead to new charges. There is no statute of limitations in the federal sex- trafficking law, which was also enacted by the state of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of young-looking girls, there may well be more evidence to uncover. (Several young women who claim to be Epstein victims have recently contacted a Ft. Lauderdale lawyer, but to date no new civil complaints have been filed.) • Conchita Sarnoff: The Billionaire Pedphile's Sex Den • Billionaire Pedophile Goes Free These new developments come one week after the publication of two articles in The Daily Beast about Epstein's pattern of sexual contact with underage girls, which Palm Beach police began investigating in 2005 and the U.S. Attorney's office then settled in a 2007 plea deal. The first 16 article quoted a deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein, a billionaire with many powerful friends, had received special treatment in both his plea deal and the terms of his incarceration. Although federal investigators at one point produced a draft 53-page indictment against Epstein, he was eventually allowed to plead guilty to only two relatively minor state charges and receive a short term of incarceration: 13 months in the county jail, during which he went to the office every day, and one year of community control, during which he traveled frequently to New York and his private island in the Virgin Islands. The Daily Beast has now discovered another instance in which Epstein apparently received special consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This is because child molesters tend to be repeat offenders with high rates of recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been disconnected with no forwarding information. The Daily Beast's second article provided details about Epstein's systematic abuse of underage girls at his Palm Beach mansion, where members of his staff allegedly recruited and paid a parade of teenagers, most of them 16 or younger, to perform daily massages that devolved into masturbation, groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between Epstein and Jean Luc Brunel, a frequent visitor to whom he gave $1 million around the same time that Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas—often from Eastern Europe and South America—are known to have been passengers on Epstein's private jets. The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his non-prosecution agreement with the federal government." Conchita Sarnqff has developed multimedia communication programs.for Fortune 500 companies and has produced three current-events debate TV programs, The Americas Forum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is writing a book about child trafficking in America 17 ,http://www.thedailybeast.com/articles/2010/07/22/ieffrey-epstein-pedophile-billionaire-and- his-sex-den.html The Billionaire Pedophile's Sex Den Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-daily massages, pornographic artwork, and hush money—that's only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive exposé. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-daily massages, pornographic artwork, and hush money—that's only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive expose. Also: • Nude images of young girls were scattered around the house and the bathroom soap was shaped like sex organs • Staff trolled for fresh recruits to make sure Epstein had two or three massage appointments each day • The house manager has been sentenced to a longer prison term than Epstein—for trying to sell notes regarding massage appointments • Epstein gave $1 million to his friend Jean Luc Brunel when he was starting the modeling agency MC2 • According to a former bookkeeper, young girls were brought to the U.S. by MC2—often from Eastern Europe—then traveled on Epstein's private jets Jeffrey Epstein's loyal friends say that his prosecution was unduly harsh, rather than outrageously lenient. They insist that his sexual habits, although obsessive and unusual, were mostly legal and essentially harmless. As the police records attest, the girls brought to El Brill° Way were routinely told they could "say no" at any time during a massage as Epstein escalated contact in a step-by-step assault that was remarkably similar in every victim's statement: First she would be asked to remove her shirt, then her pants. He would attempt to fondle her buttocks and breasts as he masturbated, then bring out a large vibrator. There was sometimes digital penetration, and the more willing girls were lured into full-blown sexual relations with both Epstein and Nadia Marcinkova, who was referred to in press accounts and police reports as Epstein's live-in "sex slave." A former bookkeeper in the Miami office, who also arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein's private jets. 18 It's true that some underage girls may have lied about their age, and some came to the house voluntarily several times—although, according to Florida statutes, none of that has any bearing on the criminality of the contact, particularly if the girl was 16 or younger. But what is particularly disturbing about this case—judging by arrangements at the Palm Beach house—is that Epstein, a billionaire hedge-fund manager, organized his life around this sexual compulsion in an open and methodical way that suggests he felt he was beyond the law. - Conchita Sarnoff: Epstein Faces Sex Traffic Probe • Billionaire Pedophile Goes Free According to police who executed a search warrant, the house was decorated with large, framed photos of nude young girls, and similar images were found stashed in an armoire and on the computers seized at the house (although police found only bare cables where other computers had been). Some bathrooms were stocked with soap in the shape of sex organs, and various sex toys, such as a "twin torpedo" vibrator and creams and lubricants available at erotic specialty shops, were stowed near the massage tables set up in several rooms upstairs. Epstein also enlisted his staff in the predatory activity, and four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged. According to police reports and sworn statements in the civil suits, all four women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein's live-in partner, also recruited young girls. Since his 13-month sentence for soliciting prostitution with a minor, Epstein has settled more than a dozen lawsuits brought by underage girls. Seven victims reached a last-minute deal last week, days before a scheduled trial; each received well over $1 million—an amount that will hardly dent Epstein's $2 billion net worth. The victims told police they waited in the kitchen to be called upstairs for a massage, and the house chef often gave them a bite to eat. House manager Alfredo Rodriguez said in his sworn statement that a maid named Lupita, who was a devout Catholic, wept when she complained to him about cleaning up after the massage sessions, picking up soiled towels and putting away the sex toys. And she was upset that a photo of Epstein with the pope hung next to one of him with a young girl. Ironically, Rodriguez, who ran the house on El Brillo Way in 2004 and 2005, ended up being sentenced to more jail time than his boss as a result of the complex investigation into Epstein's activities. He was fired, he says, for inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money. He saw an unfamiliar "beater" in the driveway one evening and called 91!. When he left Epstein's employ, Rodriguez took away some notes and emails about massage appointments as "protection" against his own prosecution, and failed to produce them during the Palm Beach Police Department's initial investigation. Unable to get work as a house manager elsewhere in South Florida, he says, Rodriguez later tried to sell this "golden nugget"—his term—for $50,000, to be used in the victims' civil suits. 19 Unfortunately, he made the offer to an undercover cop, and was subsequently charged with "obstruction of official proceedings" for withholding information that could have advanced the criminal investigation of Epstein—which by that point had been settled in a plea deal. Rodriguez was sentenced to 18 months in federal prison (Epstein was allowed to serve 13 months in the Palm Beach county jail), and now awaits an additional sentence on Aug. 24 in federal court in Miami for transporting firearms, another deal he says he made to pay the bills after he lost his job. In a deposition given for the civil suits, Rodriguez testified that he was instructed to always have $2,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters such as Haley Robson who brought them to the house. He also testified that Epstein made large contributions to the Palm Beach Police Department, and in return was given PBPD baseball hats to put on the dashboard of his various cars to avoid being stopped or ticketed by local police. Retired Police Chief Michael Reiter, in his own deposition, acknowledged that, in addition to earlier donations to the police department (which are fairly common in well-heeled Palm Beach), Epstein had recently given the department $100,000 for some sophisticated equipment. The police were still researching the purchase when Epstein came under suspicion, and Reiter ordered the money returned. (Guy Frostin, one of Epstein's local attorneys, told police that Epstein also gave $100,000 to the Florida Ballet for massages, because he was "very passionate" about massages being "therapeutically and spiritually" beneficial. Yet victims told police they had no massage training.) Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and Marcinkova "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money." (Which would amount to trafficking.) Brunel is a 50-plus French playboy who was formerly part owner of Karin, a Paris-based modeling agency. He lives in New York and South Beach, Florida, and owns 85 percent of MC2, which has offices in New York, Miami, and Tel Aviv. (The remaining 15 percent is owned by his partner, Jeff Fuller.) Brunel has been observed as a house guest at Epstein's Palm Beach home and may well have had contact with him also in New York, where Epstein owns a lavish home, and in Paris, where Epstein keeps an apartment on elegant Ave. Foch. CBS reporter Craig Pyes, who investigated Brunel for a 60 Minutes broadcast many years ago, is quoted in Michael Gross' book about the modeling industry, Model: The Li:5.g). Business of Beatitifid fPnnen. Pyes told the author that Brunel "ranks among the sleaziest people in the fashion industry. We're talking about a conveyor belt, not a casting couch. Hundreds of girls were not only harassed but molested." Now The Daily Beast has learned that Epstein had made a $1 million wire transfer to Brunel's offshore bank account in September 2004, just as he was setting up MC2. Whether this was a gift or a loan or a backdoor investment in the new venture is unknown. A French citizen who managed to avoid giving evidence in the Epstein investigation, Brunel declined to comment on any of this, as does Fuller. Asked in April of Bruners activities, 20 Epstein said "I'm 100 percent convinced that he doesn't traffic children." (Brunel has never been charged.) An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many were from Eastern Europe and spoke little English. A former bookkeeper in the agency's Miami office, who also arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein's private jets. Pilot logs obtained in the civil suits show that some of the named plaintiffs were on the flight manifests. Other times, the pilot would just list the other passengers plus "female." Editor's Note: An earlier version of this article misidentified the subject of Craig .Pyes ' investigation and the title of Michael Gross' book. The Daily Beast has corrected the subject and title and regrets the error. Read Conchita Sarnoff's oriuinal report on Epstein. Conchita Sarnqff has developed multimedia communication programs for Fortune 500 companies and has produced three current events debate television programs, The Americas Forum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Heington Post. She is writing a book about child trafficking in America. 21 http://fashioncopious.typepad.com/fashioncopious/2010/08/mc2-modeling-agency-involved-in-sex- trafficking.html MC2 Modeling Agency Involved In Sex Trafficking August 11,2010 On August 4th Jezebel ran the following story: The Sex-Trafficking Model Scout. Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money. The previous paragraph in the story read: and making [speaking of Jeffrey Epstein] frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. 22 http://bettyfokker.wordpress.com/2010/08/20/hes-helping-others-get-away-with-child-sex- trafficking/ He's helping others get away with child-sex trafficking Posted on August 20, 2010 by Betty Fokker Let's discuss that billionaire douche-face child-rapist, Jeffrey Epstein for a moment shall we? He's someone who likes to have sex with venerable underage girls, including 12 year old girls who are trafficked into the US under the guise that they will become models. His partner in crime was Jean Luc Brunel, owner and 'talent scout' of the MC2 "modeling agency". Epstein coincidently invested a million bucks in the MC2 ki.€14ie-pefn-Fifig modeling agency and let Brunel use his privet jet. The FBI thinks Epstein has assaulted/molested about 40 or so young girls. So he's going to prison for the rest of his life right? Wrong. When faced with the best defense lawyers money could buy, the prosecutors wimped out and made a plea bargain so light it boggles the mind. This kid-raping bastard only had to please guilty to two MINOR charges and gets a private cell, a cell he gets to leave on a "work release program" by the way. Now, I am not blaming his defense attorneys. They were doing their job and, under our constitution, a festering anus like Epstein has the right to the best attorneys he can afford. I am livid with the prosecuting attorneys. It was their job to do everything in their power to bring this vomit-inducing shit-sack to justice. Instead, they decided to gutlessly pander to his wealth, privilege, and powerful defense team. They rolled over and did everything but send in another kid to give this fucker a hand-job. So this vermin got away with raping 12 year old girls because the prosecuting attorneys couldn't find a single testicle/ovary to share among them. And do you know what their chicken-shit kowtowing to Epstein has wrought? It's opened the door for other child-sex traffickers to get lighter sentences for their crimes too. Why should they have to pay when he didn't? After all, it was just girls they were trafficking for sex with disgusting older males (I refuse to call something like Epstein a "man"; it insults men) ... they weren't harming anything of any value in our culture! I'm a feminist because I think girls & women have value. What a crying, fucking shame there wasn't one feminist in the prosecutors office to go after this monster and punish him. What a pity other hell-spawn might get away with trafficking girls for sex more easily because of the shit- for-brains attorneys who let Epstein get away with his crimes. My eyeballs are melting with rage. Never mind. They aren't melting. It's just tears of helpless and despairing rage against an unjust legal system and the cultural devaluation of women and girls. 23 http://zawkencom/5600294/reeently-freed-sex-offender-jeffrev-enstein-may-face-child- trafficking-charges Recently-Freed Sex Offender Jeffrey Epstein May Face Child Trafficking Charges t•r • 11 t* POtwa- ,kaasemie XFIttr 0:71/1 rg mi..tipiT WV1,1.1 -I -4! Ads by Google Expand Jeffrey Epstein, the billionaire Bill Clinton pal who just left jail after completing a sentence for soliciting sex with a minor, may be headed back soon: The Daily Beast reports that the Justice Department is investigating him for child trafficking. Epstein, famous for being rich, being friends with Bill Clinton, having an egg-shaped penis, and being a vindictive pervert, can't be prosecuted again for the charges he copped to in his plea deal. But according to The Daily Beast's Conchita Sarnoff, new charges might be coming: As we learned in Vanity Fair yesterday, Bill Clinton has spent his post-presidential life...Read more Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking-a far more serious charge than the two in his non-prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. Since there's no statute of limitations for sex-trafficking, and Epstein's predatory adventures apparently date back more than a few years, it's likely there's more women who could come forward. (Apparently some have contacted a lawyer, but nothing's been filed yet.) It's not just Epstein, either—his buddy Jean Luc Brunel, head of the MC2 modeling agency, is also being investigated, and some of the models he represented (many from overseas) may have been enlisted as companions on Epstein's private jet. 24 http://www.huffingtonpost.com/20 I 4/06/03/j e ffrey-e pste in_n_5439407.html MIAMI (AP) — Nearly a decade ago, a wealthy financial guru came under FBI investigation, suspected of sexually abusing dozens of underage girls at his Palm Beach mansion. Then, abruptly, the investigation was dropped and Jeffrey Epstein pleaded guilty to a single state charge of soliciting prostitution. He served just over a year in jail. Now, two women who say they were among his victims have won a precedent-setting appeals court ruling entitling them to see all the documents from the plea bargain discussions between Epstein's high-powered lawyers and federal prosecutors. Their goal: use those tiles to undo the agreement. reopen the investigation and subject Epstein to more charges. The women's lawyers contend Epstein got special treatment because of his wealth and connections. His attorneys deny that. Epstein. 61, made hundreds of millions of dollars managing funds for rich clients. Shortly after his 2008 guilty plea. it came to light that his lawyers had secretly reached a non-prosecution agreement months earlier with the U.S. Justice Department that spared him a potentially heavier punishment. "Our complaint alleges that. prodded by Epstein. the federal prosecutors deliberately concealed the sweetheart plea deal they made with him to avoid public criticism," said Paul Cassell. a University of Utah law professor who is representing the two women. The U.S. attorney's office in Miami would not comment. But the U.S. attorney at the time, R. Alexander Acosta, said in a 2011 letter defending his office that more evidence came to light after Epstein made his deal. "Many victims have spoken out, tiling detailed statements in civil cases seeking damages. Physical evidence has been discovered," Acosta wrote. "Had these additional statements and evidence been known, the outcome may have been different." Epstein has settled lawsuits for undisclosed amounts with many of the women who say they were underage when they were paid for sex. The case represents the first time a federal appeals court has ruled that the Crime Victims' Rights Act of 2004 guarantees victims the right to be informed about the details of how a plea bargain was reached. according to legal experts and lawyers involved in the case. The law marked the culmination of efforts begun in the 1960s to give crime victims more of a say. 25 "I hope that the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach." Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge, sold his Palm Beach home in 2011 and now divides his time between a New York City home, a Caribbean island and an apartment in Paris. according to court documents. He also has a large New Mexico ranch. He donates huge sums each year, particularly toward projects involving new medical treatments and artificial intelligence. His foundation established a Harvard University program that uses mathematics to study evolutionary biology, viruses and disease. According to lawsuits filed by some of his accusers. Epstein relied on assistants to recruit underage girls to give him massages and perform sex acts. They were usually paid about $200. Some girls were notified about the investigation beginning in 2006. But they weren't told about the negotiations with federal prosecutors for at least nine months, despite a requirement in the Crime Victims' Rights Act that they be kept informed. The two women — who were 13 and 14 when the alleged assaults occurred — sued for the files and won. "Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal prosecution do not enjoy a relationship of confidence and trust when they negotiate." the appeals court said. Federal prosecutors have begun turning over the documents. Epstein's attorney. Roy Black, the celebrity lawyer who is also representing Justin Bieber in his DUI and resisting-arrest case in Miami Beach, declined to comment but has asked that the documents be kept from public view, and so far they have been. In a May 23 court filing. Black said that there was no conspiracy between prosecutors and Epstein's team to violate the victims' rights law and that the non-prosecution agreement contained many provisions Epstein strongly opposed. such as registering as a sex offender and agreeing not to contest certain lawsuits. "This was no sweetheart deal by any stretch of the imagination," Black said in court papers. Even if a judge invalidates the plea deal, it will still be up to federal prosecutors to decide what to do. "The court can't force the prosecutors to bring charges," said Matt Alexrod, a former federal prosecutor now in private practice in Washington. 26 http://www.huffingtonpost.com/conehita-s-sarnoff/ehild-trafficking_b_1269748.html Conchita Sarnoff Communications expert Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, nublished "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunelts latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to prevent depositions. "Trawling for 511" underage teenagers to work for his agency. MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: 27 we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a 'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross's 1995 book, describes Bruners activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journal magazine. In that stor‘ "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!" Ford recalls. "But went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." http://jezebel.com/5603638/meet-the-modeling-agent-who-trafficked-underage-girls-for-sex The Sex-Trafficking Model Scout 28 xpand Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a prominent modeling agent and scout. Here's what we know about Jean Luc Brunel. Jeffrey Epstein, you will no doubt recall, is the man who thought ferrying Bill Clinton on his private jet, lawyering up with superstar Alan Dershowitz, and making frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Say you're not as famous or celebrated as Roman Polanski and you want to sexually assault...Read more Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. But as Conchita Sarnoff wrote at The Daily Beast: Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money.' The FBI investigated Epstein, and identified around 40 underaged victims. Sarnoff reports that the FBI is also investigating MC2 and Brunel for possibly engaging in child sex trafficking. Since pleading guilty to reduced charges of soliciting sex with a minor and serving 13 months of 29 part-time jail, Epstein has become the focus of numerous civil lawsuits from his victims. He has so far settled a dozen. These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper, a number of the girls worked for MC2, the modeling agency owned by Jean Luc Brunel, a longtime acquaintance and frequent guest of Epstein's. Brunel, along with numerous young models, was a frequent passenger on Epstein's private jet, according to flight manifests. The agency owner also allegedly received $1 million from Epstein in 2005, when he founded MC2 with his partner, Jeffrey Fuller; although Fuller and Brunel denied any such payment from the billionaire pervert in 2007, when rumors started swirling, Sarnoff got confirmation from a former bookkeeper at the agency. Whether the money was a secret investment in MC2, or a payment for Brunel's services as a procurer, is unknown. Brunel also visited Epstein in jail. So who is Jean Luc Brunel? Although he did not respond to our interview request, we spoke to a number of people who have worked with his agency. While MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either: MC2 in New York most recently launched the career of Latvian editorial star Ginta Lapina (Brunel "discovered" Lapina via an MC2 scoutina competition for young teens) and currently represents Vogue China covergirl Liu Dan. Worldwide, MC2 represents such stars as Sessilee Lopez in Miami, and top models Candace Swanepoel, Marina Lynchuk, Natalia Chabanenko, and Elisa Sednaoui in Tel Aviv. Brunel isn't involved with the business on a day-to-day basis, although he owns an 85% stake in MC2. Instead, "Right now he does scouting for [the] agency and takes care of the international relations with other agencies," reports one source. Scouts scour the world for un-agented teenaged girls who could make it as models; they work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight — even relative to the almost totally unregulated modeling industry itself. "He travels a lot," says another person who has worked with Brunel. (The company blog refers to Brunel as a "scouting tsunami." and MC2 is fairly well-known for the strength of its international scouting.) Models we spoke to report mostly positive experiences with Brunel — one praised his sense of humor and said he is "lovely to all of his models," and another described him as highly intelligent and cultured, adding, "he knows a lot about the opera and he paints" — although it should be noted that none of the models whom we spoke to had been told of either his connections with Epstein, or his past. And what a past it is. These accounts from Michael Gross' 1995 book Model describe Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karins, now known as Karin Paris: "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karins was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always 30 been on the edge of the system. John Casablancas gets with girls the healthy way. Girls would be with him if he was the butcher. They're with Jean-Luc because he's the boss. Jean-Luc likes drugs and silent rape. It excites him." "I really despise Jean-Luc as a human being for the way he's cheapened the business," says John Casablancas. "There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano...They were very well-known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." It should be noted that aside from being a professional rival, Casablancas, the founder of the agency Elite, was eventually drubbed out of the industry for his own modelizing. How pervy do you have to be for John Casablancas to call you a perv? Pervy enough to drug and rape numerous teenagers, according to 60 Minutes and Diane Sawyer, who investigated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel andJor by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that Brunel and/or his friends had drugged and raped them. Said producer Craig Pyes, "Hundreds of girls were not only harassed, but molested." When Gross interviewed Brunel, this is what he had to say for himself: "You get laid tonight with a model, is that a crime? I don't understand why people go into your personal life, what you do yourself, and to yourself, and they don't look at things that are really important." Since then, Brunel has been involved with a succession of agencies in New York and Paris. Although the 60 Minutes scandal eventually led Eileen Ford to stop working with him, he continued his involvement with Karins. In 1988, when powerhouse agency Next opened its doors, Brunel took an ownership stake. He also "discovered" Christy Turlington when she was 14. MC2 is only his latest venture. Because no criminal charges were ever filed by any of his accusers, and because the industry has a short memory — most models working today weren't even born when Sawyer and Pyes started looking into Brunel's activities — Brunel has been free to continue as he pleases. A French citizen, he even avoided testifying in his friend Epstein's trial. And so Brunel is still criss-crossing the globe, trawling for 5'10" 13-year-olds from Eastern Europe and (the NA, h iter parts of) South America. And apparently taking the occasional ride with them on Epstein's private jet. Is there any better argument for the regulation of the modeling industry? http://nypost.com/2011/11/18/j effrey-epsteins-level-3-sex-offender-status-upheld-by-ny-appeal s- court/ 31 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 20111 5:00am Multimillionaire pery Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New York does. A state appeals court yesterday upheld the financier's status as a Level 3 sex offender — meaning he's considered "a threat to public safety" and a "high risk" to offend again. Epstein, 58, did 13 months in a Florida jail for soliciting a minor to perform a sex act on him during a "massage." Although he was never indicted or convicted for hiring any other underage girls, the state Appellate Division found there was "clear and convincing evidence" he had indeed done so, making the Level 3 designation appropriate. 32 http://pagesix.com/2007/10/06/model-shop-denies-epstein-tie/ MODEL SHOP DENIES EPSTEIN TIE By PageSix.com Staff- October 6, 2007 1 9:00am THE owners of MC2 models are denying industry speculation that massage maven Jeffrey Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, who was once accused of taking advantage of underage models. Epstein, who this week agreed to plead guilty to soliciting underage prostitutes at his Florida mansion in a deal that will send him to prison for about 18 months, reportedly gave "millions" to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. "E equals MC squared . . . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out," said a model industry insider. "He's a desperate old man that fantasizes and takes advantage of young girls." The trouble doesn't stop there. Karins Models founder Brunel, who's currently a partner in MC2, denied allegations in a 1997 "60 Minutes" segment that he took advantage of young models who were high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2, says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 15. He also dated Linda Evangelista when she was a teen. "He's also involved in the agency," said the source. "Gerald and Jean-Luc like the same things. They hang out because they have young girls in common, like two guys who enjoy the same wine." MC2 president Jeffrey Fuller confirmed Brunel was a partner in the company, but denied any working relationship with either Epstein or Marie. "We have no relationship business-wise with Gerald Marie. Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and 1 are the only two partners and owners of MC2 Model Management," Fuller said. Epstein's rep said he was not involved in the agency. "He has no business relationship with them," said Howard Rubenstein. 33 http://www.palmbeachdailynews.cominews/news/lawsuit-doeuments-link-jeffrey-epstein- to-modeling/nMGzHi Lawsuit documents link Jeffrey Epstein to modeling agency owner Jean Luc Brunel By Michele Daman Daily News Staff Writer New court filings in a civil case filed by billionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel, owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all over the world, promising them modeling contracts. "Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent," the documents say. Through the investigation of his lawsuits against Epstein, Edwards learned Brunel "runs the modeling agency MC2, a company for which Epstein provides financial support," the documents say. They also allege Epstein tried to thwart Edwards from taking depositions of Brunel, Epstein's companion Guislaine Maxwell, and other high-profile names such as President Bill Clinton. Details are listed in more than 62 pages filed by attorney Jack Scarola on behalf of Edwards in the lawsuit Epstein filed against Edwards. Edwards represents four of Epstein's minor victims, three of whom have settled their cases with Epstein under a confidential agreement. Epstein attorneys Christopher Knight and Joseph Ackerman declined to comment Friday on the court filings. Edwards deposed Brunel, but his attorney delayed it and then said he was back in France with no plans to return. But according to the court papers, Brunel was staying with Epstein in Palm Beach during that period. 34 The court filings describe Brunel as one of Epstein's closest pals. Regarding Maxwell, the documents refer to sworn testimony by Epstein's former house manager, Alfredo Rodriguez, explaining how Maxwell took photos of girls without the girls' knowledge, "kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims." According to the documents: Maxwell allegedly lied about her mother being ill and having to fly back to England one day before a scheduled deposition in Edwards' case against Epstein. Despite that assertion, Maxwell was captured in a photo for OK magazine, attending the wedding of Chelsea Clinton two days later. Epstein has settled more than two dozen lawsuits and claims against him by young women who say they were lured to his El Brillo Way mansion as teens to give him sexually charged massages and/or sex in exchange for money. The terms of all settlements are confidential. Rodriguez took a journal from Epstein's computer that listed the names of his underage victims from around the country and the world. Calling it the "Holy Grail," Rodriguez tried to sell the journal for $50,000 to victims' attorneys. He pleaded guilty to obstruction of justice and is serving 18 months in federal prison. Epstein, 57, served 13 months of an 18-month state sentence. He ended his one-year probation in July on state charges of soliciting prostitution and soliciting a minor for prostitution. According to flight logs from Epstein's private planes, Clinton flew several times on Epstein's planes, many times with Maxwell, Palm Beach resident Sarah Kellen and Adriana Mucinska — "all employees and/or co-conspirators of Epstein's," according to the court papers. The documents show that Clinton flew with Epstein, "then suddenly stopped — raising the suspicion that the friendship abruptly ended ... "Epstein's personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him ... and what appears to be Clinton's personal numbers," the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards' client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time, Doe was so frightened that she fled her home in the company of a retired police officer and was taken to a hiding place, according to the court papers. http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ 35 That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I've been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), I learn about, it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trqfficking Trafficked Athletes And now a new one I should have seen coming. Those very young, foreign models you see? Some of them were trekked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory trekkers; Go to politically or economically unstable areas; locate 5'l1" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. It's hard to think of an area of our society that doesn't admire seeing it's most vaunted members with a model on their arm. While this observation does not imply that those people were trafficked, imagine how simple that makes it to approach a child or it family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. I'm not shocked at traffickers using this method of promises to lure unsuspecting girls into slavery, I've seen it, read about it, studied it. I'm in shock that it flourishes in the most visible, 36 glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she 's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Samoll Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to 37 prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a 'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journaimagazine. In that story "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!" Ford recalls. "But I went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." 38 http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I've been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), I learn about , it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trekking Trqfficked Athletes And now a new one I should have seen coming. Those very young, foreign models you see? Some of them were trafficked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory trqffickers; Go to politically or economically unstable areas; locate 5 '1 I" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. It hard to think of an area of our society that doesn't admire seeing it's most vaunted members with a model on their arm. While this observation does not imply that those people were trqfficked, imagine how simple that makes it to approach a child or it's family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. 39 I'm not shocked at trqffickers using this method qfprornise.s to lure unsuspecting girls into slavery, I've seen it, read about it, studied it. I'm in shock that it .flourishes in the most visible, glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she 's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Samar Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges 40 have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models.