on 11 THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA

on 11 THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA O IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY. FLORIDA MUM e4 ays. U DISTRICTS ❑ OTHER PLAINTIFF(' JEAN-LUC BRUNEL CML ACTION SUMMONS (b) Form for Personal Service on a Natural Person VS. DEFENDANT(' JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG CASE NUNN& 14021348CAO CLOCK Rd THE STATE OF FLORIDA:TO EACH SHERIFF OF TIE STATE, YOU ME COMAANDED to See Elm Swain al S Taff/ 0/ lie Cpnpil4 In thla lawsuit on ereloniant: To Delanclanit JEFFREY EPSTEIN I Aisremeuk, -Wrint) ciiee 4-2.* ' 358 El Bab Way On Bead% FL 33480.730 -a se-ret 4:tisiti-tratt I VAC BIE21TME A Iowa* hes boon Ned ad eau yes. You has., 20 uWnM1w days Sr this summons la served on rat to Me a wain reedy sa I attsUrd complaint with the dere of Um court A phone CM .40 not pulsar./ Tax written response, ectucling the came number SCAM end nu tomes of the pertly must be Mod if you want Me coal to Nor your Side of the nee. If you do not Me your tint you may lose the case. and your wafts. money arc pr party may Orrearier be taken without further swig from the Coin We Cdhsr Sepal nquimmente You may want to call an enceeey ape away. If you do not know on Storey. you may as an paean set Ore legal ad offal fisted in an %am V004 If you diode to fib a written nreorna rase( at me snout fie your erten reSCOnScr wdh Me Clerk of Me Cast. r mail a lake a arm of your tendon /spacebar. 'Planter Attorney named holow. The rad& location of dm the Dade Coady Cowthouse. The address for the . act kicatcos are fisted tem for your ra DADS COUNTY COURT LOCAnOtes ®be, Ow* Cass". e61 O.1.amth CM CC (30) Ross ,33 Noma 103 73 MS Fisja seed sem mw a Assn lam,. •W.1, 1213C aria. IWO. 32142 ElYam Wei Oman Can Os) O care caw Ousts Cod psi Res 200 Arm 100 1130 wastimagol A.w.ie 3103 Pees Os Ise NI Masi lack Fiona. Iii Ca0 a RIOS 33134 I11msh Min (21) Room 100 11 Ent 611•Sbeel 1.114•04. Flo," 330111 PlalrelPlairtiff Attorney JOE IfTONE Florita Bar No. 203882 HARVEY RUMN CLEM( OF COURTS O .1mM On Atoka Comm 1/31 Room 100 Isles Room, 131W. Mei Moo newt nonce um 0 Seat Deis Amass Csalm Del Ross Om lona ON 211 SIRS away "Isla IMO SERVICE Addis: 821 M. STH STREET, POMPANO BEACH. FL 33080 VERA snicsitr DEPUTY CLERK fr.ai 0920,7N the Oven don NOM anal ebo ▪ ai AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order to it olio participate in this proceeding, you are entitled, at no cost 1 o the provision of certain assistance. Please contact the Eleventh Jud al Circuit ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW Ave. Sui e , Miami, FL : 3128, Telephone (305) 349-7175; TDD (305) 349-7174, F (305;349-7355 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711." CUMT 07o leer Wit Iamb eitimat aresidadartran EFTA00599855 O EN LA CORTE DE CIRCUITO DEL UNDECIMO CIRCUITO JUDICIAL EN Y PARA EL CON DADO DE MIAMI-GADE LA FLORIDA o EN EL TRIBUNAL DEL CON DADO EN Y PARA CL CONDADO MLAMI-DADE, LA FLORIDA DIVIMOti 0 MAL l] OMA EMPLAZAM/ENTO DE ACCION CML (b) NOTIFICAC1ON PERSONAL A PERSONA NATURAL DEMANDANTE(S) VS. DEMANDADO(' NUMERO DE CASO HORA Demandado(.: HISBIStrE LAOS ha Wo demandado iromineme. Tin 20 da, cadet* a pak Oei recto de Ms mitecaden. para eenbader la dereanele Wan& Pet aele. ~aria arde oste Mant Uni pateada lelefOnica no b protegera. Si tata diste que el Miami urmden su danse dabde Vaarder Su rtsPuesta Per et‘no. Itackayerrdo el namen del cao y bs nombres do a panee Ireenamdes. SI tated no tonale le dealende banco. tabee parrclet el raso peul rla 501 deepeeedo da sin k9(5505 ypIDpiedid135. 0~0 de spa deredios, tr steno aviso del bemat &eten aree and:secs legt. Wodan. aaide meed consultar e In abapalo inmedatamerde SI ro coma a tm ~do. puilde Wren uns de las eilaas de aatimaaa lepel Dna Nd Office) o un soeks° da referenda de aboaadea (Attomey %terra Servet° que spermen en guia lekNonea. SI daas 111007150f e Ie demanda por su asemt al mismo Liza en qua poesta' su reeuws-ta a* ei tribunal, dera talud enviar pier COMBO o eallregar en la mano ima copla de su raspuesta a la persons dencenineda ab* ome Atlant( Momenten» o Miegel° dei DernandentOyprosenlar w coreetacon ad deinende al Secneado del 'luisde. La utaicson centra' nu la Mina dei Sárodanb este en ei edididede ta Cate dei Genood/. de Da*. La direadon de la Cate. y de las sucursales ~een mat/aa siodente part su comeniencu : LOCAUDAD CE LOS MOUWES DE. COIMADO DE OASE 0 aa alt, ~na 105) D Jota Ca Ca OOI n la Ca AS Cas. (731 eta~ ~te all Roos 133 Roca 103 qat Im Olourn 130 73 Wed nflet Stmol sado MM 71 Aa 15555 eiscaym ene. MEEN) 51)51-ont ~a Modoe 30130 hisore, Pla 3330 M.a Ye. lkoon netd• »OIO man las rini" ❑ asara ~ei orna Cao« (1)) n L. Card am Ca mn Ct5) O sant adde Judas Ca OM ns to» Ra. 100 Ra 1110 1130~ dama 3103 Pal On Le. me MI/10 OS 211 Sa al sem Mondo 0130 Cad Ga ~de 71114 nroln 33.10 Dernandenle oAtopedo Od Demandante DirecciOn: Numero del Cdegio de Abogados: EL ESTADO DE LA FLORIDA: A cada Sad! del Estado: Se le ordena que hagen entrega de esta notifiC3CiOn y u Ma de b deinende en este 511110WdlifiltaldOle flteredOrdell HARVEY RUM Senegal(' del Tribunal del POR: Condado COMODOCeelario Atijunto Ley para Estadounidenses con incapacidades "Si usted es una persona miausválida que necesita hater arreglos para poder parbeipar en este proceso, usted tiene derecho, sin gasto alguno, a que se le provea certa aguda. Por favor póngase en contacto con el Coordinador de ADA en el Onceavo Deitrito Judicial ubicado en el Lawson E. Thomas Courthouse Center, 175 NW lst Ave Sala 2702, Miami Fl 33128, Teléfonos (305)349-7175; TDD (305) 349-7174, Fax (305)349-7355 por lo menos 7 dias antes de la cita filada para su comparecencia en los tribundles; o anmediatamente después de recibir esta notificación si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacilación del &do ode la voz, liame al 711." FECHA CIWCT 070Rer 11111 IffiabeddrecamnitabioNdernalerli.ceni EFTA00599856 0 AU TRIBUNAL DU ONZEME ARRONDISSEMENT JUDICIAFtE DANS ET POUR MIAMI DADE FLORIDE. O AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE MIAM-CADE. FLORIDE DIVISION 0 CMLE 0 AUTRE PLAINTE() A (AUX) ACCUSER) CONVOCARION a ACTION CMLE (b) LIVRAI ON PERSONNELLE A UNE PERSONNE NUMERO DE CAS VS. CONTRE ACCUS3) HEURE IN ADRESSE: IMPORTANT Des poursuites judiciaires ont ete agiotas atm vota. vous avez 20 fours coraucts parer a de ka da de de aile citelion pour deposer nie response ease au plante Sente aspres de ce blutai. Un smile coup de telearee nid Naissant pin vous palet Vous etes Mais de Nia« VOMI, marne ta, nec mena du mana de dosa ch-dessus el du nom des ales manses id, si vous souhaitez que in bibunal entende vote causa Si as ne Mati pas coots repense eat dans le ai roda vous ratez de perdre u taus. ainsi que atm saliens votre nient awl Na puma uts sass par la sa, auzun puma ulleneur du tribunat I y a dautres obligations juridiques et vous pouvez redue& Ws »Mecs intrellas d'un avocat. Si vous n• coma ismii pas de vocal. voue pOumez »Mahomet a un stria MOMMVental (fiants ou a in biseau tram:Sanaa jenkledue (figurai • rarnualre do WephonteS) Si vote Choisissez de decca vousarne ire repense cette a vous faudra radernert, en mena bangs quo cette forma, faim parie nit ou espace« une copie de vote Merda Allonwe (Plaignant ou asatvocas at) =Mn ci la votre iraavec le Grollim du Tribunal. para du bureau du Greffer a Dade County Coulthixae,Illit eedgu Inn ment des usa:unsles sont dans u dessous pour are osa rua ACIRESSES 1PMINNO( 194 da O DM Corn Caunnom mie O arin Cil. ce MI 1n Rem lea Noah Ose Sale CAMilur. ROM In Ream34 Haie na nu SoM Rats me cola ni New /3 Win stn. Pa t 544el W4 2/ Menue Rem lee see,see,pow art ISSU Navre fa. mer new' 'bru 231 p t tint ern Sena swere ras »Omo D MM Ne» Otte Cam IN/ D Cal Gaies Ibild Gan CS) Li ses os. Wace Ca (1» Rem 3•3 Mann Mg Rem Inn II» WoMongion Asa Na Poix* or Lm. end Une Zak 111 Sne kW» Ose. noies MI» Cal CS nom WIN hW» Ridas NI» Plainte/Avocat du Plainte Numero de barreau de la Ronde: LTAT OE LA FLORIDE A chaque eherif de roast vote etas oblige de presenter cette citation et une photocpie de la platinas fo ce document sur recouse (e) a-desta Adresse. HARVEY RUVIN Greffier do Tribunal PAR COPIE 13fflefER AMONT DATE ON: ACT DE 1990 POUR AMEWCAINS HANDICAPES AVIS DE r ADA "Si vous êtes une personne handicapée qui a besoin d'accommodement pouvoir participer Iatte procédure, vous avez le droit, sans aucun coût, d'avoir de disposition. al vous plaît contacter le Coordinateur de l'ADA du Tribunal de Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW in Ave. Suite 2702, Miami, FL 33128, Téléphone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 au moins 7 jours avant la date de comparution au tribunal, nubien immédiatement après avoir reçu cet avis si la date avant la comparution est moins de 7 jours; si vous avez une incapacité pour entendre ou parler, appelez le 711." Œ/4C7.070 Ray 11111 Caca siebeddre« wantemideded•Wee EFTA00599857 MN TRIBUNAL ONZTEM AVVONDISMAN JIDISYE MAN E POU PAIAPSDADC COUNI Y. FLORIDA 0 MAN TRIENNAL E POU TRIBINAL IMAN MUUSDADE COUNTY. FLORIDA. DIVIZTON U SML 0 LOT PLENTIFII) KONVOKASYON POU KA SML (b) DEUVRE PERSONELAIAN BAY VON NIOUN VS. KONT MUA) NIMEWO nA ADRES: Eagarl LE Yo entre yon aksyon kont oumeum. Ou genyen 20 jou kalandnye aptes ou recevoi sornasyon-an pou enregistre b evan greRe tribunal-n. yon renonce pa cal attache avec plenta. Yen apel Pa Melon ka kapab grolege-ou. Se yen repense pa ecritio ou ma mimero ka-a lei sou tel pagaie avec yo lei sou papie-sa oblige esi si ou vle ke tribunal-la Ande position-ou coujoa6SI pa enregistre neponos-ou a ou capab pedu ka-a sen tribunal la pa OnCRITtC01-012 ed yen. ou capab pedu IM ou ale byen ou. Genyen lot demande. Ou ka besoin telefone yon avoka tout de suit. Si ou pa lonen yon avala. ou ka rele sein kl rekernsede avoka, ou dro edu regel (lu flan lis liv nierons). Si ou Moisi voye yon renoncer pa mai oumanm. ou supose on mem tan poste en mem tan poste on pote on Copi retapons. pa eut pou avoka pleyan ou pleyan-yo ke norNi ama-a et enregistre repooœ-la nan tribunal-la kl Ricane nan svek Sbkrete Tribinal. Admis amiral biwo Secrets a se Dade County Courthouse. Adres bibiruil la, ale adres lot tribinal yo nan lis lei 1 nba a pou ou ka jamn yo aber ADRES MIMAI- HAN DAM COURT' n m. Caser Caraimi• fte1) 0 Joue Cale Canar (NO 0 Mat DM Jais Came CM Ro= 133 Rte 103 Rom 100 73 Wall Rader Strie Se MW 22 Mitron 1$563 PernreBntl 111a fana 1f1! 11mM, Rama 33142 ara MM OMM. Rate 33160 13 Mise lise Mima Coda MM 0 Cati 0•11« Oint Cota MS/ 0 Soue OIS AMY» Cela pel Rem 200 itse 100 flœm 1200 1130 aailwiton Moruo 3100 lems ne WI aM M710 Da 211 Star Mea IMIIM rl.a MI 30 fiml 0SS Hama 33134 10001*. Patate 101a1 LI 1001•M Olottla f2t) Room 100 II Fe« 610 Mme MONO. noble 330,0 Railla/Avocat du Plainte Numerus de barreau do la Ftride: ETA FLORIDA: Pou Chak nan eta s yo odane ou peu bey akta e (yo), nan I dot 81111.0 a. manda na* yon Ø yo pote nase sa il. Mme nain noka a. Address: flat HARVEY RUVIN Selerata .leneral TrIblml La BAY: SEKRETE DATE: LWA 1990 POU AMERIKEN KI ENFIM AIMONS POU AMERIKEN ICI ENFIM "Si ou se yon moun Id enfin' e ou benwen akomodasyon pou ou patisipe nan pwosedi sa a, ou gen dwa pou yo ba ou kèk &I sari ou pa gen pou ou peye. Silvouplè kontakte Kowôdinatè ADA pou Tribinal Onzyèm Distrik Jidisyè a nan: Lawson E. Thomas Courthouse Cent«, 175 14W le Ave., Suite 2702, Miami, FI 33128, Telefan (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan ou gen randevou pou ou paret nan tribunal la, oubyen imedyatman M ou resevwa notiftkasyon sa a si o s gen mwens ke 7 jou pou ou paret nan tribunal la; si ou gen difilcilte pou ou tende oubyen pale, rele 711." altrat. 070 Mer 11n1 met RØ se« rruneelaasteSenen EFTA00599858 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 EPSTETN. TYLER MCDONALD. TYLER MCDONALD D/B/A/ YLORG 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: I. 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)(I) ("long-arm") authorizes service on both out-of-state Defendants (Tyler McDonald. and Tyler McDonald d/b/a/ Yi.Org). EFTA00599859 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 EFTA00599860 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. II. 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 I 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 EFTA00599861 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 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 EFTA00599862 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. 2I . 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. 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 24. 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 of the website Jezebel (Composite Exhibit A. p.2-7). 5 EFTA00599863 25. The deposition testimony of 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 ■. 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 Docs). 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 EFTA00599864 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 &' 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 I 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 EFTA00599865 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 with a local psychologist, Dr. Royce N. Jalazo. as a result of Epstein's actions and the negative results on his business. (Exhibits N & O 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 YLORG 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 EFTA00599866 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 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 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 stale 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 EFTA00599867 websitcs 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 arc 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 I 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 I through 44 above are re-alleged and incorporated herein by reference. 10 EFTA00599868 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 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 EFTA00599869 COUNT IV - EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDQNALD Dift/A,YLORG 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 YI.ORG 75. The allegations contained in paragraphs I 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 EFTA00599870 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/ YI.ORG 80. The allegations contained in paragraphs I 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. /s/ Joe Titone Joc Titone Attorney FL BAR #: 203882 621 51h Street Pompano Beach. Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) Joetitone708ecomcast.net 13 EFTA00599871 VERIFICATION STATE OF FLORIDA COI JNTY OF/C2.4.4eI e/he ) JEAN-LLIC BRUNEL. being duly sworn according to law. upon his oath, deposes and says: I have mad the fore-going complaint and all the allegations contained ther/in All such allegations um true based upon my personal knowledge, infurtnutioy and belief. i Sworn and albscribed to before me this / day ofe,,,,e,a-r- , 2014. 1 — ... -- VMLAbWJ Nay St-Pilo el MX Or kes• Sim 0c/ 31. 2016 Calm 0 It 2901. !oriel limp NSW Mean** NOTARY DBLIC 6 14 EFTA00599872 COMPOSITE EXHIBIT A 15 EFTA00599873 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 ofJustice 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.) • 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 EFTA00599874 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 SI 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." C'onchita Sarnabr has developed multimedia communication programs for Fortune 500 companies and has produced three current-events debate Tit 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 I7 EFTA00599875 http://www.thedailvbeast.com/articles/2010/07/22/jeffrey-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-dail masse es, pornographic artwork, and hush money—that's only now being revealed. reports on the sordid details in part two of her exclusive expose. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-dail masse es ornographic artwork, and hush money—that's only now being revealed. reports on the sordid details in part two of her exclusive exposé. 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 Brillo 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. Ile 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 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. I8 EFTA00599876 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. • 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. E stein also enlisted his staff in the predatory activity, and four . and --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 SI 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. Ile was fired, he says. for inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money. Ile saw an unfamiliar "beater" in the driveway one evening and called 911. When he left Epstcin'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 EFTA00599877 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 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 Di trict of Florida, an alleged victim said that Epstein, Maxwell. Brunel, Rodriguez, and "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, Afodel: The l'uly Business of Beautiful Women. 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 $I 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 Brunel's activities. 20 EFTA00599878 Epstein said "I'm 100 percent convinced that he doesn't traffic children." (Brunel has never been charged.) An American fashion desi