Vermont Service Cartier 30 Havgision Sires' Saint Alban rer 05011 Re: 0-1 Etertxvcinary 103110 as cn Ad Meek/ Toient Coordinator on behalf at Jean-Luc Cr tlerwiliene Brunei TO Silvan tt may Concern: As a President al fiataBe PAWNS Management tvi tenet is fitornoted in waiscst es mC2 models mzrr.. LIC or Denott ot mi. Jim Luc asurffaP ft wok as an Art Director arid Tamen, Coadnalar. sat Brunei hold; co ritemotienol repitallon CtS oVISIbk. CkCitegiC nelerotter who is obse to cullivase evert fosalionsila management skill cedar 10 conteXt Dullness Via giatal ereinxweerd avi tvolier luoratree deals. hir inter has 0 long testacy in maiming and atIvertiong /Tao ladian campaigns Tryoughok.i his twerriplive yew career In lee fashion bushes& us. Brunei has developed vitifft•vidt ISCS:StvisrdI crld cosmetic comp:Ion" Sone of these maior casnedIc ccimpolcrs include; o Therm wen eiparritodel Be mcPowno4 f41104,S with RebeCco kw*. Chilean OW talith Christina Semonnorskom Margret Asia viiith Monica Meucci, Monet Win Potticio Von Rickonheim. Angel Pedume with Triseny hissfer. and Cot:hotel Parikene VAN' Aldo Sokoto. S. &run& has do, demaidPad rnalor fashicel campaigns cind has clvelOped campaigns end attar** contacts wilh some of the rvoltCrS 10p koshiCal clessgnors SuCh cIS Yves ScIrd sward. Chanei. Christian Dict Gucci Prado. ond Marc .i0c0Os. ji&.4-ji-ntaro MAIM Ur lorittlAta.13 ailla a /a, 407.3 V.1011 'Areek44 lair 3 an Psi arm. .11. psi Jssm, puts netagrelopplal,_ "WY., nalss aarn-cdath. Qin 1,414X0iLIS241, & PARLIKSS IONA Lads PARSAW forts a 16 nal gixo ci• A en WOW to tic Joan Lac guide's eiders*. bLisifiele MOW Cs an incilvkilai with *MSc Alm eV ONIelvetoiu,i4 1161 MOW Plint MO top tookiart elcAseis so nsprissont et Ms tinted Slates- Mead 'Mu hove any gumboils about Mr. Man toe Slung feet iree lo cardact mu, ii Vermont Service Center Attn: Premium Processing Unit 30 Houghton Street St. Albans, Vermont 06478-2399 Facsimile Transmission To: LUIS FONT Cirtzenshi and Services Fax Number: 19542414272 Number of pages including cover: Date: September 6, 2014 From: Email: Receipt Number: Vermont Service Center — Premiirn Processing Unit Fax Number: W2-288-1778 W.; PREMIUM PROCESSINGODHS GOV Phone: 1-865-315-5718 Attached you will find a copy of cu decision concerning your case The original decrsion will follow via mail If eligible to appeal our decision appeal forms mil be included —Important—Important-4'lmportant—Important-** If responding to a Request fa Evidence or !lent to Derry. ensure you include a copy of the decision immediately following your cover page and indicate the total number of pages included with your response Please include the case receipt number (e g EAC01 000 12345) with all correspondence Ensure when responding to this request that you fax your response to our NEW FAX NUMBER - B02-238-1778 if you wish to mail a response, it must be sent to the VSC Premiirn Processing Unit at 30 Houghton Street, St Albans, VT 05478-2399 Do not send your response to the 75 Lower Weiden Street address, as that will cause delays and will not restart the premium processing clock until the response is identified as a premium processing case Title 8 CFR Section 103 2(b)(11) Submission of evidence in response to a Service request states All evidence subenMed in response to a Service request must be alornitted at one time The submission of only some or the requested evidence will be considered a request for a decrsicn based on the record This communcabon a ritended far the sole use of the individual to whom it is addressed and may contain inforrnabon that a prmleged confidential and exempt Iran disclosure under applicable law If the reac, of thrs corrimunration is riot the rlended recipen1 or the employee or agent for delvering the communication to the intended recluienl you are hereby netted that any drssernrialion distrkiuton or copyrig of the communication may be strrtry prohbled if you received this comrnunrcation ri error please notty the sender arTracirately by telephone arid return the communicator alume address above use Lin led Slales Postal Servre Thank you www.uscis.gov U S Department of Homeland Security U S Citizenship and Immigration Serviirs Nonce ot Action Page I of 4 Applicant/PetItioner A # Appncation /Pent ;on Petition For A Nontninitp,rarit Worker Minn 'a Notice Date August /6 1014 Response due by November 21, 2014 MC2 MODELS MIAMI LL( LUIS FONT FONT LAW GROUP PA .1440 HOLLYWOOD Ita 511 41j HOLLYWOOD IL ,1,1021 1-4 At. I 4Z. Z55(iN().-1 -EAC14/255u803 Applicant/Pelitiotier MC2 MODELS MIAMI LLC beneficiary BRUNEL JEAN LUC Receipt Number EACI4//550803(II 19) WVIUM PROCESSING IMPORTANT THIS NOTICE CONTAINS YOUR UNIQUE NUMBER AND MUST BE SUBMITTED IN TliE ORIGINAL WITH ITtE REQUESTED EVIDENCE 1 U S Citizenship and Immigration Senaces iUSC1S) requires additional evidence to process your form Incase provide the evidence listed on the attached pagets) For Form 1-129 only, if you are requesting consulateembassy notdication, provide the requested evidence in duplicate 2 Your respe must be received in this office on or before NoNeinbef 11 1014 Please note the required deadline for providing a response to this Request for Evidence The deadline reflects the mzumum period for responding to this RFE HilWetiet, since many immigration benefits are time sensitive, you are encouraged to respond to this request as early as possible but no later than the date provided on the request You will not be granted an extension of time to submit the requested evidence 3 You must submit all requested evidence at the same time If you submit only some of the requested evidence, L'SCIS will consider it a request for a decision on the record [8 ('FR 103 2ib1t II ii 4 You will be notified separately about any other applications or petitions you have filed 5 From the date this office receives your resubmission, a minimum of 14 days will be required to process your form If you have not heard from LISCIS within 30 days, you may contact this office at r866) 3[5-5118 6 Mad this nonce and your response to VSC heiruuni Pressing Vermont Semce Center 30 Houghton Street Si Alb-ans VT 05478-2390 vs- premium piote”iniatihs Qv U S Department of Hornefrind Security U S Citi2enship tind IMrnigrdtion Servites Nonce of Action Pagc 2 of 4 EAC14ZZ550803 (!jig! ___________________ Responses flor Preini um Processing cases only) may beloxed to (8Q2) 488-1778 Include a copy al this notice Thee inail address may only be used for inquiries Do not send responses to thee mail address I. I d9 0- Ili Extraordinary Ability in the Arts 1 ou MCZ Models Miami LLC hied Form I 1Z9 Fetilion lor Nonintringrant Worker seeking 0 lit MII)Ift11111gRI11 classification liar Jean Luc Brunel as an Art Director / 'latent Coordinator The 0 .113 classification applies to individuals with extraordinary ability in the arts The individual must have sustained national or international acclaim His or her achievements must be in the tiekl of expertise and show a record 01 prominence in his or her lipid 1G process your pennon and determine ml the beneficiary is eligible additional information is required 1 his request provides suggested evidence that you may submit to satisfy each requested nern You may Submit one some or all ol these alenis Submit none at the suggested items and instead submit other evidence to sa1is4 the request Explain how the evidence in the record already establishes eligibility Request a decision based on the Ter071 Note poweveLthal, yQUIff ff5PPMfble lqr PrOviding evidence thatlksi shows thaLyo and the pIrtie ipstin_pplitigh meet all requirements Evidence must show that all parties were eligible for the requested benefit when you filed Form I 149 General Requirements Inr All 0 Nomintrugrant Petitions In general petitions seeking 0 nonimmigrant classification must include Copies of ontracts A description ol the competitionts) event (st or pertormance(s) and At least one consultation To saint, these requirements you submitted - Your letter in support ol the petition and Peer letters in support al the beneficiary trom Claudia Muloto and Alla Amaniova Beneficiary s Previous 0 - 1 Status Petitions involving an extension al status lor a beneticiary that has previously been gt al.te (I 0 1 nommringrant status may he given deference however U S Citizenship and Immigration Services (USC1S) is authorized to question extension petitions when a substantial change in circumstances occurs when relevant lads change lrom one petition to another or when the prior approval may have been based on gross USCIS error )ou militate that the benenciary was previously granted 0.1 nonimmigrant status with your company The details of the beneliciary s previous employment with your company are not documented in the instant petition A review of the evidence submitted indicates that it the beneficiary's role within your organization has remained unchanged the previous petition may have been approved in error. as the list ol duties you provided do not appear to descnbe a FOR oFFKI USE ONLY Form I 797 (8/03/90) Y U $ DeparlInciit of HOrrtland Security U S Citizenship and Immigration Servic es Notice of Acnoti Page 3 of 4 MC14/4550803(1 I Z91 position in the arts In addition DO evidence has been submitted to support your claim that the beneficiary is an individual who has extraonlinary ability In the ails that has been demonstrated by sustained national or international acclaim Yu have documented the beneficiary s past success in the business of tot ming and operation modeling agencies but this evidence points to the benetiriarys ability on the field of business not the arts Therelore you are asked to comply with the following Contracts Pennons seeking 0 nonimmigrant classiftratton must include a copy ol a contract between the beneficiary and either the petitioner or the Pmpioyer II a wniten contract does not exist you may submit a detailed summary of the terms 01 the oral agreement between the beneficiary and either the petitioner or the employer You did not submit any evuleme lot this requitement You may still submit evidence to satisfy it Wniten COniraciS or the summary of the Innis of an oral agreement must specilv the terms and conditions ol the employment or services They must Specify the wage altered antl explain the terms and conditions under which the benetictary will pertorm these services, and - Detail any additional services provided Nature of the Event or Engagement 'Jou must provide an explanation of the competition event or pertomiance in which the N./IMP-My will participate An event means an activity surh as a scientific project conlerenre convention lecture senes academic year or engagement during the requested validity period The description you submitted is insufficient In your latter you list the duties at the proffered position as 10'SpOnS11)1e 101 overseemg the artistic aspects at the agency (select the images placed on the model, business cards ,:nd in their porilohos) Coordinate the pairing of models with photographers Direct the marketing of models to chents Travel around the world 10 tint-Over new Ulm( and 10 sign them with MC Z Models and Establish relationships with agencies around the world and negotiate representation agreements The duties you descnbe appear to relate exclusive!) to the maintenance ot business cpvrations of a modeling agency As previously stated you have thxumented the beneficialy s past success in forming arid operating modelmg agencies however this e kicience points to the beneficiary s ability in the held 01 business not the ails It is not evident therelore that the 0 18 noturturagrant classification is appropriate In the inSlanl case Regulations define the 'arts" as any held of creative activity or endeavor such as but not limited to line arts visual arts culinary arts and perfomung arts Ahens engaged in the held of arts include not only the princtpal motors and performers but other essential persons such as hut not limited 10 directors Set designers lighting designers sound designers choreographers choreologists conductors orchestrators coaches arrangers musical supervisors costume FOR LARK £ US/ ()NIA Form I 797 (/O3/9O) /* If 11 Deo twin of Homeland Sr-runty U S Citizenship (ind immigration Servii es Notice of Action Page 4 of 4 MC14 a 550803(11/9) ___________________________________________________________________________________ designers makeup artists flight masters, stage technicians. and animal trainers The duties you describe correspond to business anti management fUTIMOTIS DOI to a position In the arts Before adiuthcation of your petition can proceed this discrepancy must be resolved You may still submit evidence to sanity this requirement The desknplion must include An explanation of the nature of the events or activities. Beginning and ending dates at the events or activities. and A copy of any itinerary that shows dates name(s) ot the employer (s) and location of the event (s) You mot establish that the proffered position qualifies as a position in the arts as described above Any and all claims must be Why supported by documentary evidence FUR ,FFP.. I USE uNLI Form 1797 (8/03/90) Y FONT LAW GROUP, P.A. 3440 Hollywood Boulevard, Suite 415 Hollywood, FL 33021 Tel.: (954) 241-4271 Fax: (954) 241-4272 November 3. 2014 Director United States Citizenship& Immigration Services Vermont Service Center 75 Lower Welden Street Saint Albans. VT 05479 RE. NOTIFICATION OF WITHDRAWAL OF 1-129 PETITION WITHOUT PREJUDICE BY PETITIONER EAC-14-225-50803 Petitioner: MC2 MODELS MIAMI LI.0 Beneficiary: JEAN LUC DINER HENRI RENE BRUNEL Dear Sir/Madam: Please be advised that this office represents the above referenced petitioner and beneficiary in this immigration matter and a G-28 from our office is on file. THE PETITIONER, MC2 MODELS MIAMI LLC HEREBY NOTIFIES USC1S THAT IT WISHES TO WITHDRAW 1-129 0-1 PETITION #EAC-14-225-50803. The petitioner requests withdrawal of this 1-129 petition without prejudice. Please note this request for the record in the above referenced case. We respectfully request that you send us verification of this withdrawal pursuant to the regulations contained in 8 C.F.R. Sec. 103.2 (h) (15). Kindly send our office a written verification of this withdrawal located at: Font Law Group. P.A. 3440 Hollywood Boulevard. Suite 415 Hollywood. FL 33021 Thank you tbr your attention to this matter. ---- Original message From: Jeff Fuller Date:11/12/2014 11:49 (GMT-05:00) To: Jean Luc Brunel Subject: RE: New York Jean Luc, I am really sorry you feel so bad and I know it has been a mental and psychological frustration. As you know I chose to partner with you due to your reputation in the business for being a top scout and developing a couple world class agencies in the past. I knew what you could bring and I knew what I could bring and contribute and I thought it would be a great partnership. Clearly, I never expected to have the level of challenges we have had recruiting new models over the last several years. I could have never foreseen the problem of your friendship with Jeffrey Epstein turning into the situation it has where you are seen as guilty by association when you have never done anything or even been convicted of a crime. Frankly, I don't understand the necessity for Conchita Sarnoff or anyone else to continue to defame your name and MC2 by association. It is true that we constantly have to justify ourselves when recruiting new models. The industry is extremely competitive and as a parent myself if faced by the same information and having to make a tough decision between too agencies I would not pick MC2 if I saw the article online about you. You have to read closely to see there is not a charge against you but the implication is strong and of course now days everyone believes everything they read online even more than the traditional newspapers of the past. I know you are now feeling like a liability to MC2. But you personally are not a liability to MC2 but this published information online is a liability. We are not a large enough company, nor do we have the capacity to fight this on a global level. On a google search in America we have put enough information online to not have it popping up so blatantly but we have no controls over the rest of the world or the finances to control this situation and we are affected as every major model agency recruits it's best models from all the various countries abroad. This has stunted our growth and our billing over the past 6 or 7 years. In fact, we do not even know who avoids us based on finding this information. I have been surprised how challenging it is for us to grow due to this problem. I have also had a tremendous amount of worries from our clients that we are vendors for that are large American corporations likes Kohls, JC Penney, Sears, Nordstrom, Target, Neiman Marcus, Macys, Saks, Belk, and so forth that require vendor agreements and for us to be considered an upstanding company. It really worries me as some of those companies have disassociated themselves from what EXHIBIT K they believe to be questionable companies. So far that has not been a problem but it could come up in the future. The fact that you are requested for so many scouting events in various countries and cannot promote yourself properly to promote MC2 in the press due this problem has it's own sent of repercussions in terms of our global branding. In short, it has had a terrible effect on MC2 all around. I really urge you to solve this problem and get this removed from the internet so we can grow for the future. I've fought for MC2 and been extremely loyal but I must confess that I have even been feeling inadequate and questioning my ability as the leader of the organization. I can only attribute the fact that we have scraped by in the recession and barely survived in the past to your hard work, my hard work, and the tenacity of both of us combined. I can only imagine that if I am feeling inadequate and frustrated over a lack of growth of our company that you must feel even worse as you have had much greater success in your career and have operated at much higher standards in our industry in all areas from reputation, respect, admiration and monetary gains. I can even surmise you are probably feeling a level of depression and I have seen it in your highs and lows and when you have voiced your frustration. While I know you well and recognize you don't really go for the kind of advice I will offer; however, I think you should at least speak to someone neutral such as a therapist or a counselor to let your frustrations out and if you don't feel better and are still feeling down or depressed to see a medical doctor for your condition. You are such a positive person I hate to see you fighting what you feel is a hopeless battle. It is not hopeless you just need find a way to get that information offline and begin to repair your reputation. In the end I am afraid the damages are a lot more than you realize but let's keep fighting and moving forward as we have no choice. Thanks, Jeff Jeff Fuller President MC2 Model Management USA EXHIBIT K FROM: JACQUIE JOHNSON <.J.JOIINSONaiRRA-LAW.( 'OM> DATE: SEPTEMBER 18, 2009 3:57:44 PM EDT TO: "'TAMAQTKUDNIANLAW.COM" CC: "BRADLEY J. EDWARDS" SUBJECT: EPSTEIN - DEPO OF JEAN WC BRITHNEL We have confirmation for Mr. Bruhners deposition on 11/3. We will commence at 10:00 a.m. if that is ok with you. Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeldt Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale, FL 33301 Telephone 954 315 7264 Fax 954 527 8663 JiohnsonOrra-law.com EXHIBIT L ---Original Message— From: Tama Beth Kudman Date: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <2jeanluc@gmail.com> Subject: Re: Hi >All depos are cancelled for now. A letter confirming this is being >Sent out today. We have no idea how long this shall delay things. I'll >let Michael know. > >Sent from my iPhone >Tama Beth Kudman EXHIBIT M From: "Dr. Royce Jalazo" To: joetitone708@comcast.net Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an outpatient individual psychotherapy session with me on 12/12/14. Thank you, Royce N. Jalazo, Psy.D. Licensed Psychologist Dynamic Behavioral Consulting a DBA of Dr. Royce Jalazo, P.A. 1975 E. Sunrise Blvd., Suite 532 Ft. Lauderdale, FL 33304 Direct (With Voicemail): 954-232-7092 Toll Free Fax: 888-236-6979 or 954-208-3400 E-mail: DvnamicBeh@qmail.com Website: www.DynamicBeh.com EXHIBIT N jtosa...i60 SCISkIll tWNIib Scuion rrred Or.EessedSad _Pe-,c nteim J'affit°PriAt I-1rg DIC T110,1: an 4. tit.* di Mot !SMik 'IMMORAL L, t'ONSULTING etychii*enempy_______yasuahom_____________entiskillatiterws Clio* Strike skin #: MOOD. ras ehrfsr LhInv LaNyrnic _$eztieliAnt ficiic106 _____ Otivrt fTpn AFFECT; 4,Act-A ANyurmitc Waited RI:sin:Jed neat 1Prusevis Idenandtwit,istetinit Dynamic 4wIir Cossaidgeg 1P5L Semis* Blvd, Wilt 512 Litseeniske awl& 33304.1413 Data T 1s4 TH FR SASH Tim lh I S n.ns. oir: ILIIL p.sti. Donstlan:O tninuto Apegrvuy-- sligirly Intense ter:Itirczt I E Ch4cnuuu mteounk aPP'). LIZAAir ifILL48, Was pasiezt Neirovwf tor psyciturg- evaltsaton amitr-ggni-ki end in prm-rthrciproSotrYrt- me:41-a4:ign Fir,',113-2:11.11 te Frnent!, mon-vornplive 0 V EDI annrnctit- Is ptteci ctirnani taking ps)vbx,-*E rrodicationt: DD ii, Pcenc: Cornplisat N'A a N Cartrs--4 NIOTIVATI(YI FOR TRE 4,TMENTtriaNGE:__________ 14J14, inotimod fli3u,I,bty m*1m Dii,rt DISPOSITKIN: o Conmlur Ttvacalcnt Termitaiten treetmex 0Reef le 1 Ottl-et: ot 04A.•.,.11., LAM 11:44444-L4e . iteyeeN Imo, Pt) ID Immo Fsocsaistaz PY1611 EXHIBIT 0 Ussonatinsed COMPOSITE EXHIBIT P MEDICAL HISTORY tagarifil°4411.1"." ki*/ • *re eg4 Wel it Wel W4,1111, " }I: ft " 0.41 6" • 44-0 teid.11.601401011%"!‘ • - pa I P. 1'P e. .6i6411: 14444: W11 10+66..0* la IOW& SA •pf ;La UP+ 4 Wylie 44,4 410 • • .ab • IVA ;' Pa On I. 4;1 ij 11'41-7-w4" 41 Vol /0 44-4P4`41.4-1 1111444111 1f imt anion minuswiq 4511151(1I1Oist•i+.44)-4rIpiv5 se ) /144.10" m.40.n• 0•04m1"4eulte — .4eir — WOW,-- at" , 00 Inn LIMO ( I hirim, V WOW (.1M2111M Sb 111$1.41)1111,1JUS:01..0111.1 (WO titnarattriuntsit • MO? AN' a c.744.• • + V,T1 .. .444 4,a it tirftr+11411,14.4.4,1 I VU44114x-r•ilv.• 1-131, 11 I I "ARO •414.4.4 '141444 PIP'04411110$141114111.0.1' Iii 1."41c+11411 1 444,14.141N 41.0144.4+4 la 4111,, I I-N.114411 WI I - 44'4 II 411% goingteuttnamo 1VIldSOH MN NH fsowEntnatli5thav BNH HOSPITAL1NR 31 soict lava (Bangkok Ntaing Homo Hospital) MR. JEAN - LUC BRUNEL Prozac (20 Mg) Capsule # Take 1 Capsule Once Daily After Breakfast 0141221248 02/12/2014 135,53 Tel. 02.680-2700 Fax. 02432-0S17-9 wend ON tnwEran BNH H .c, „„ (Bangkok Nursing MR. JEAN LU Rivotril (2 Take 1 Tablet Once Daily Before (It May Cause Dr EXHIBIT Q EscortAgeosy. ft/Or =doling money owriat ion. Luc &t4nai who covana Oat LIC2 meactcy in Miami Sawn, &wort Mho Woe to Ingot and firml lhamaehitia ontinarad ta a itvAnclarwalbola:644/as.yi ottgoituido-llorda abo-ikialapaltorgtoliancioloricia-1, filic011- 1410,Cyl- triggir gelEscort In Floctio Thri mist popular grown-up 014 awed inmitia %item topottad by WOriv. .. Fiend') =doling loamy oovnot Jean. Luc Brunei, who co-owat tha MC2 nsawy 4:acv-tiLeAtIcrect‘arkai fl ofgrirjat- -Mi4.,Gitrointiaa-abc-sta3.apa yi.tagigal S ascott in rionda NovtUnAkinagijings1Ert Sinew- laritkils *ice inroad, Moict radio niativinet drop Icktilas from , French modeling agency nwriet ilamseptuo lininet who ork-awna Intt14102 agancy inP 11714 air Moors ttbc- scS-opit 7$,4~,4-Drinotilvmhuni-be,410 _ • 0%60.03 Ii1heara-abc4el$, apayi itrboirito- rniekraik-bnalcry 'mar%) d4rs.or PAWNoftwakin nal. Mate Iacono ant legitimate prolassiortniti Rand) matialtig ;loamy &Arno joan,Luic Isruniol./Alho crpoing ft* AiC2 hrjoino hi ?Atom 004‘ch oticesite.;044mettA" -10 orgickrea, vvitotium yi worms Inc-actin" 5imjlig I - ;.-e- • 0.J 41.,4411, '" ' uvehat J.gø Lta 4%1M11, Vriio colymta lila MC2 Agart4m libittni fiaach aboa Oar Yea i Citillo Florida Etiebeil , 41itytive 9,01 eirtp 114101114)110rfv5ilr.irI Yt, 11 .1`., rttwi • • t iiiiLsOe lit ESCQL1-1 miseak bend., Illagida *scans in. No Strinps Atsactioa c reni-41 friothoit%0 eifirrtiv aft on-owniv A4C2 army - 1044as„ rdige liozwpet g1L =gm. owe; fi tda. gaiong EXHIBIT Q http://www.politico.com/blogsiunder-the-radar/2014/12/court-filing-levels-sex-claims-at- alan-dershowitz-200495.html Woman who sued convicted billionaire over sex abuse levels claims at his friends By JOSH GERSTEIN I 12/31/14 6:38 PM EST A woman allegedly kept as a sex slave by politically-connected billionaire investor Jeffrey Epstein, who went to jail for having sex with underaged girls, is accusing several prominent friends of the financier of having taken part in the debauchery, according to a new court filing. The woman—referred to in court papers as Jane Doe #3—leveled the allegations Tuesday against Harvard Law School professor Alan Dershowitz and Britain's Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel. Dershowitz flatly denied the claims about him Wednesday in an interview with POLITICO. It's totally, unequivocally and completely false," the celebrated attorney said. A spokesman for Prince Andrew denied the allegations Friday, while a lawyer who handled related matters for Maxwell did not respond to an e-mail seeking comment. Representatives of Brunel's modeling firm also did not reply to e-mail messages. The accusations came in a long-running lawsuit charging federal prosecutors in Florida with violating a victims-rights law by failing to consult with Epstein's victims before signing off on a plea deal. That pact ruled out any federal prosecution of the investor, who agreed to plead guilty to two state prostitution-related felony charges. Lawyers for the victims have described the arrangement as a sweetheart deal the well-connected Epstein and his high-powered legal team achieved by putting pressure on prosecutors. Epstein served 13 months of an 18-month sentence on the two state charges before being released in 2009. He's now a registered sex offender. The new court filing, submitted by Florida lawyer Brad Edwards and former federal judge Paul Cassell in a federal court in West Palm Beach, Fla., asked that Jane Doe #3 and another woman be allowed to join the pending case over the victims' rights claim. "Epstein...trafficked Jane Doe #3 for sexual purposes to many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3 to describe EXHIBIT R the events that she had with these men so that he could potentially blackmail them," the court filing said. "One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein's and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin Islands," the legal pleading added. Dershowitz called the allegations "totally made up and totally fabricated from beginning to end." He said he was not in the places described in the filing at the relevant times, with one exception: he did visit Epstein's private island in the Caribbean on one occasion. "I was there with my family," the renowned law professor said. Dershowitz said in a follow-up interview after this post first appeared Wednesday that he's planning to file bar complaints against Edwards and Cassell for inadequately vetting their client's story. "I'm planning to file disbarment charges against the two lawyers who signed this petition without even checking the manifests of airplanes or travel itineraries, et cetera," he said. "I'm also challenging the young woman and the lawyers to level those charges against me outside of the courtroom, so that I can sue them for defamation.....Finally, I'm challenging the woman to file criminal charges against me because the filing of false criminal charges is a crime." The motion accuses Prince Andrew of similar actions, asserting that "Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls)." Previous press accounts have reported on Prince Andrew's friendship with Epstein, who was known as a philanthropist and supporter of scientific research before the criminal investigations began nearly a decade ago. However, the earlier accounts stopped short of accusing the prince of sexual involvement with girls Epstein procured. In a 2011 Vanity Fair story, Prince Andrew denied any such contact. While a Buckingham Palace spokesman did not respond to POLITICO's query about the matter on Wednesday, the palace issued a denial to several British news outlets Friday. "This relates to long-standing and ongoing civil proceedings in the United States, to which The Duke of York is not a party. As such we would not comment on the detail. However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue," the statement said. Prosecutors said in a 2007 draft letter they'd identified 40 young women who could be considered victims of Epstein's illegal acts. Many of them filed lawsuits or claims against Epstein and reached out-of-court settlements for amounts that were not disclosed. EXHIBIT R While "Jane Doe #3" is unidentified in this week's court filing, her story appears to track with that of a woman who sued Epstein in 2009 and settled with him later that year. She apparently granted an on-the-record interview to Britain's DailN Mail in 2011. Some of the fascination with Epstein on the part of tabloids and glossy magazines stems from his ties to former President Bill Clinton. In 2002, Epstein provided his 727 to Clinton for a trip to Africa to study anti-AIDS programs. Celebrities such as Chris Tucker and Kevin Spacey came along for the ride. The new court filing makes no mention of Clinton, Tucker or Spacey. The federal investigation obtained manifests for Epstein's private jet travel, but prosecutors never charged anyone besides the investor with involvement in obtaining or using underaged girls for sexual purposes. The new court filing says this result is in part due to the fact that Epstein's legal team—which included such heavyweights as former independent counsel and solicitor general Ken Starr, trial lawyer Roy Black, and Dershowitz—negotiated a deal that precluded the feds charging anyone as a co-conspirator. Lawyers for Jane Doe #3 argue in the new motion that Dershowitz put this language in the agreement to protect himself. However, the law professor told POLITICO he didn't negotiate that deal and it wasn't aimed at protecting him. "I had nothing to do with drafting the non-prosecution agreement," he said. Dershowitz added that the last draft of the agreement mentioned four people by name who wouldn't be prosecuted and he was not among them. All were regular associates or assistants of Epstein, the lawyer said, adding that the final language removed those names and simply barred federal prosecutors in South Florida from going after any potential co-conspirators. Epstein and his lawyers fought hard to prevent records about his plea negotiations from being turned over to victims' attorneys. However, U.S. District Court Judge Keith Marra ruled last year that the victims are entitled to examine those records to prepare their case against the government. Epstein, Black and others appealed that decision to the Atlanta-based 11th Circuit Court of Appeals, but it ruled in April of this year that no privilege protects plea negotiations in this sort of dispute. Edwards and Cassell did not respond to requests for comment for this post, including an inquiry about their response to Dershowitz's comments. However, the pair appear to be pressing forward with the victims' rights lawsuit, which seeks to unravel the no-federal-prosecution deal cut for Epstein in 2007. UPDATE (Wednesday, 7:18 P.M.): This post has been updated with further comment from Dershowitz. EXHIBIT R -------- Original message-------- From: Abi Schwinck Date:16/01/2015 05:16 (GMT+07:00) To: Pink ,Jean Luc Brunel „Jeff Fuller Subject: FW: Victoria From: Erik Bechtal [m ai Ito : erik@pageparkes.corn1 Sent: Thursday, January 15, 2015 5:12 PM To: Abi Schwinck Subject: Victoria Hey Abi1 Hope you're well. : ) I've just had a conversation with Victoria, and she isn't comfortable remaining with MC2 with all the drama going on right now in the press. She's asked me to contact you on her behalf. Please let me know if you see any issue with this. Thanks so much! Erik Bechtol Agency Director Page Parkes Houston v‘, w.patleparkesage ncy.com The Page Parkes Building 1535 West Loop South, Suite 110 EXHIBIT S Houston, TX 77027 P: 713 807.8222 F: 713 807 0055 EXHIBIT S