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

fal IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA. Ej IN THE COUNTY COURT IN AND FOR MINALTIADF COUNTY. FLORIDA 0 CIVIL U DISTRICTS O OTHER CIVIL ACTION SUMMONS (b) Fenn for Personal Service on a Natural Person CASE 11.113EP 1402134ISCAO PLAINTIFFS) JEAN-LUC BRUNEI. VS. DEFENDANT(S) JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG CLOCK W THE STATE OF FLORIDA:TO EACH SHERIFF OF TIE STATE, YOU ARE COMMANDED to sane EH Sinn* ameaboley of lie COmfialal this tarrHill on dated:tat In To Ostandangsy j JEFFREY EPSTEIN El Addrale: eqe, le ef. O, .• EW-ike 4-z 3n1-4/ 351 Billie Way Palm Beach, 33410-4 0 Siaret #!vti II41-stigia Aorta mmerreza A Iowa* has been Ned no a.lretl You. 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The address for the courthouse, and taiinthkCaticts are Wed brew for your carnelian®: CADE COUNTY COURT LOCATIONS tie )Nen on also is G Garb Coates P:61 O.1•••••• Caleb CS (301 0 0100 Oody mom cams Int SERVICE Roes 733 WS 103 Rem 100 73 wee P)Ja Sari 3030 KW 22 Maw liSSS Biscayne 8hd• — finch El x How. nos 33142 1400 aim nuke. FloOlb 11103 0 Men we, Dana Can al) 0 Gni GS awe Can DS) 0 11070 ems raw cow cm Item Ho a oen KO Rags IMO t13011/711,0,7/CA •WFJ• 3103 WO a Ise en 10710 86, 211 Sari Yon awn .svm. The Caw GS RIMS 33134 10a F 33103 0 IMMO CS (21) Room 100 11 NU Sin Dna Mai* Floe 3:Will PNInellFlaintiff Mornay JOE TROVE Florida Bar No. 203882 Address: 621 S.E. 5TH STREET. POMPANO BEACH. FL 33060 HARVEY RIMH limn ISAING1-1Et : DATE Ott ELS 0 9 CLERK OF COURTS DEPUTY CLERK 20 15 AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who _needs any accommodation t inro:fsgern participate in this _proceeding, you are entitled, at no cost. to you,_ o_ the p _. certain assistance. Please contact the Eleventh Judicial Circuit ADA Come& Lawson E. • house W 1 2, Miami, FL 23128, to p lator, Telephone TDD Fax at least 7 days before your schedu e sou • ppearance, or MON a ely upon receiv ng time before the scheduled appearance is less than 7 days; if you impaired, call 711." his notification are hearing or if the voice CM= 070 Nee Wit OelesesbakInet wwsw EFTA01122242 O EN LA CORTE DE CIRCUITO DEL UNDECIMO CIRCUITO JU DICIAL EN Y PARA EL CONDADO DE MIAMI-GADE LA FLORIDA 0 EN EL TRIBUNAL DEL CONDADO EN 'e' PARA CL CONDADO MLAMI-DADE. LA FLORIDA DIVENON 0 CIVIL OMA EMPlAZAMIENTO DE ACCION CML (b) NOT1FICACION PERSONAL 01 PERSONA NATURAL DEMANDANTE(S) VS. DEMANDADO(S) NUMERO DE CAS° HORA Dernendado(s): MPORTANTE Usted ha We dernandsde leipanenie Tune 20 dat cortedei e ~ir del recto de Ma ~adert para ~Ms, Ia domande ~Na. Por °solo. y Pnaerda da arde egt inbula. Urm boude Weerga ne b protegera. Si ~d desee qua el ~d armere su *Se Proscillar su resFuesru por ett. Iltl.~0 el menen> del ~yin nomhzes do Lis Ine iremealas. SI tatud no ~tem Ie tienpo. miese poon. el casu poid na eer deepclodo de sus Ingre505 ypinpiedellea. 0 ~0 de sus derediee, sn previo aviso del beaat Existen ceres itquisee legalas. Si lo des. wede IS consult/ratel ebewelo inneceatamenie SI ro ~stat Myriade puede knar • una de les ollände de aseiontia koel (Lagal AM Olfloe)oun segbecio de reforencle de abogadoe (Attomey Referte! Servan que warmen en Is etria lekNonea. SI dan ~ander a ie ~anda ps sti ast, al M25000 tkártp0 *fl quo ~Sta Su ~at& mto el eiburial, debeire talud envár pp ~en o enlrepar en e mano tra copla de su raspuesla a ia persona denornineda ab* wee lalainerePlantiffs Allerner (DemardanleoAbcgsao del Dall0000100) y 07170.30017 w catetesan a u ~ende al Sealt:b del Jwyado. La utikacloo coca do la Mina dei Sároraeb este en el «sado de la CtrIe del eend/do de Dode. La direaion de la Code. y de las cacursales maan on ia boa aglienoi punt au comeniencir : LOCAUDAD Ce LOS TIOBIUNMES Dfl COMIADO DE DADE O oen Cal, Caárli~ (05) D ~Mi Ca Ce 1301 n ~h 0a Jas ~er (231 IJ ~am aai 01) Roos 133 Ros 103 ~n KW Roem 130 73 Va nat Ser 140/ 71 Aam 15555 Raiyee 0553 ll EER) én 31-).. Mna 71orkie 30130 syn-.bs 33142 ah Mom lbootn nes. 3.11110 R10•••• 11oRs 'nr." ❑ 1.1.19 ~ei 00•n C.« ra) Gas 0~3 w1 osi LT st.n. mara Cali. (201 Ra 300 Rea Im Ns 1303 1130~ Raa0 310) Parie Oe la *cl 36/10 Sr 211 Sta ~I `dl Rondo 333» Cad CableR ~de 33114 Mia R1/4043 33110 Detnandenle oAtopedo Od Damandante Direccion: Numero del Cdegio de Abogados: EL ESTADO DE LA FLORIDA: A eada Sad! del Estado: Se le ordena que hagen entrega de esta notficacion y u ta ode de le deinende an •10 piib el 71015017~9(7) 771~015057 ambo HARVEY RUVIN Secretarie del Tribunal del POR: Condado COMO Beenden° Adninlo Ley para Estadounidenses con Incapacidades "Si usted es una persona inhausválida que necesita hater arreglos para poler partcipar en este proceso, usted tiene derecho, san gasto alguno, a que se le provea cierta ayuda. Por favor péingase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial ubica-do en el Lawson urtho NW 2702, Miami Fl 33128, Teléfonos TDD Fax por lo mens 7 dias antes de la a ga a para su comparecencia en los r una e_; anmediatamente después de recibir esta notificacién si el tiempo antes dc la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitación del &do ode la voz, !lamt al 711." FECHA CUUCT D70 Rei 11111 ClerVe Wr adthrse we nam dadel( dorn EFTA01122243 0 AU TRIBUNAL DU ONEEME ARRONDIE:MENT JUDICIARE DANS ET POUR ISAMIOADE FLORIDE. O AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE TENA-DADE FLORIDE DIVISION 0 CIVILE 0 AUTRE PLAINTE(S) A (AUX) ACCUSE(S) CONVOCARION DI ACTION CIVILE (b) LIVRAI ON PERSONNELLE A UNE PERSONNE NUMERO DE CAS VS. CONTRE ACCUSE(S) HEURE IN ADRESSE: IMPORTANT poursuites Manu ont ate enterprises œntru aura. vous errez 20 fours coraeorots a parer a de ka dire de rassIgration de ale Cabal pour deposes une response ease a ta pro (Seine aptes de ce Mine Un secte coup de teleçœne est nellisant pour vous prenez Vous ewe oasis de depose batte anise talle, nec menin du numem de douer *dessus el du nom des battes noroises id. si vous souhaitez que in tribal enterait von Causa Si as ne agate pas este repense ecrite dans In Mi nette van natta de perdre YI couse muez que sen salaire votre arpent et vos ben pomma en usa pas la sa, axai primats ullenaur do niai. Il y a daubes obligations juridiques et vous pouvez roquet Ws satins iniffellatc d'un avocat. Si voie ne connaissez pas dace. voue pOumez lekephOrM a un .avive relatante cavala ou a th butas dam:stance )aequo (Routard a tarnualte de teuton«) Si sa Cheistssez de demis« ww-rnewa ive none, calte. d va faudra egalesnert, en ment bimps que celte formate, faim pans nit ou axpedIer une copie de von aorte esta au liamtlf/Plaines Attorney (Plaignant w a sen avocat) narine ciMeSSOU5 et IMegere votre reportes awe b Cirta du Tribunal. L'adresse watt du bureau du Greffer est Io Dada County Couilhouse. L'adresse du tharseet redresse des succursales sent *ana ci-dessous parr sotte oonvenen ADRESSES DES tRIOUNAUXrN da O DIS Cam, Cavons, 105) G Man Cab Canar (20) n Mod. or s, Canar an ( ) >luis nia isq Room 134 Mes 103 ROM in ROM 100 r3 rem ftegbe use sue W. 22 rate ISSU encaver end. ln tionniMSWM sud. now Un» sur MM 3:1142 /Me mmo Mum Ç 2310 mise. flmedn 3301s D MM "mn outil Can IN) D Cal Gia tau Gail QS) Li tan osa Jante cana da) mas MI Men Mi Mon tac II» Welmen Musa 3100 Porto of Lim ami 10110 St ill Sr 'MM Osa Flonda nia Cal OS VIMY MU Morat Mens MIS Plainte/Avocat du Plainte Humer° de bureau de la Ronde: LIAT OE LA FLORIDE A chaque te il de refait vota etes otage de presenter cette citation et une photocpie de la plaines te ce document SW recouse (e) a-destes. Adresse. HARVEY FtliVIN Greffier do Tribunal PAR: COIME GIEFFER ALUttaT DATE ON: ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE I' ADA "Si vous êtes une personne handicapée qui a besoin d'accommodement pour pouvoir participer à cette procédure, vous avez le droit, sans aucun coût, d'avoir de l'aide à votre disposition. S'il vous plaît contacter le Coordinateur de FADA du Tribunal de l'Onzième Circuit Judiciaire, Lawson Eassak6sithottse W 1" 02, Miami, FL 33128, Téléphone I ffl; TDD Fax au moins 7 jours avant la date de comparution au tribunal, onbien immédiatement après avoir reçu cet avis si la date avant la comparution est moins de 7 jours; si vous avtz une incapacité pour entendre ou parler, appelez le 711." OMET. 07o Rev (lilt dort% webinlabanc wimMninidedeSrli.Con EFTA01122244 0 NAN TRIBUNAL OfIZYEM ANNONDISMAN .11DISIE NMI E POU kausoAnc COUNI Y, FLORIDA 0 NAN TRINNALEPOU TRIBINAL NAN MIAMI-DADE COUNIY, FLORIDA DNIZYON U SML 0 LOT PLENTIF(S) KONVOKASYON POU KA SML (b) OEUVRE PERSONELAIAN BAY YON NOUN VS. KONT AKIZE(S) NIMEWO KA AtOZE: ADRES: LE Yo entre yon aksyon kont oumeum. Ou genyen 20 jou kalandnye apres ou recevoi somasyon-an pou enregistre c ovan grebe tribunal-sa, yon reponse pa eat attache nee plent-la. Yon apal pa teletan ka kapab prolege-ou. Se yon repents pa alto ou ma numem ka-a ki sou let pagela avec nom rurune-yo ki sou papie-sa oblige esi si ou vle ke IribunaHa !Bade position-au cou ka-a. SI ou pa enregistre noponotfrou a Mauro ou capab pedu ka-a san tribunal le pa anounce-ou or' yen, ou capab pedu ragen 01/ Mc byen ou. Genyen lot demands. Ou ka besoin !arena yon avoka tout de suit. Si Ou pa Conan yon awl's. ou ka role sate kl ntkonsaride evoke, ou dro edit legal (kJ nen le liv talons). Si ou shots/ voye yon memos pa ecsi oumenm, ou supose On mem tan poste en men, tan posts on pole on copi response pa sal pou evoke ',Sayan ou pleyan-yo ke norNi ama-a et enregistre reponee-la nan tribunal-la kl localize nan svek Shkrete Tribinal. Adres amber biwo Secrete a se Dade County Courthouse. Adres biblical le, ak rakes lot Iribinal yo nan lis ki r nba a pou ou ka peen yo titer. ADRES TRIBBIN. NAN DADE COUVRY 13 Nat cane ~Ms K6I 0 Wok CS Whor We) 0 tens ors AS Cs Oh Roos 133 Res 103 Woo 103 73 WS Hagler SI SOO) NW 12 Sown 13063 Nrilymt ONO IS Row. Sitt WM. WS 33742 NoW Mood Ow" RS WOO a wr WO. Mon Cowl 00 0 OW Oaem Oln Cool (15) 0 3M, INW WOW WIN 001 RS 200 Rs 100 ROOM IWO 11)3 WiNwiton Nwew 3103~ Os Is *is •0710 W 211 Wm my., flwm 331M OW OS. 7~ 33134 YmN Pae.ctu WOO LI Sires moat PO Room KO II Emi MYam ISO. F-11010 PlainlalAvocel du Plainte Nina de barreau do la Florida ETA FLORIDA: POO Chair nan eta s yo odane ou pau bay aka a (yo), gala anwo a. manda sa a ak yon kepi yo pate nan pease as a. HARVEY RUVIN ni L y:~rate Jean) TrIblnal La "" LWA 1990 POU AMERIKEN KI ENFIM ANONS POU AMERIKEN Kl ENFIM "Si ou se yon moun lei enlim e ou bezwen akomodasyon pou ou patisipe nan pwosedi sa a, ou gen dwa pou yo ba on kilt ed san ou pa gen pou ou peye. Silvouple kontakte Kowådinate ADA pou Tribinal Onzyem Distrik Jidisye a nan: Lawson Ebous W ågamsigja.2702, Miami, Fl 33128, Telefon TOD Fax =0~ omwen 7 jou enven ou gen randsva I pou ou paret nan tribunal la, oubyen Imedyatman le ou resew/a notifilcasyon sa a si o t gen mwens ke 7 jou pou ou paret nan tribunal la; si on gen difikilte pou on rande ot byen 11 pale, rele 711." Nimes*, minim evoke a. Address: DATE: SEKRETE CUf/CT 070 New IVII nemt'* ort0 soldreno wow many OaoWer‘ com EFTA01122245 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). EFTA01122246 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 EFTA01122247 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 EFTA01122248 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 Plaintiffs behalf was an e-mail dated August 27, 2010 from 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 EFTA01122249 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 EFTA01122250 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 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 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 EFTA01122251 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 EFTA01122252 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 & 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 EFTA01122253 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 Brunel'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 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 EFTA01122254 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 EFTA01122255 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 EFTA01122256 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 EFTA01122257 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 S.E. 51h Street Pompano Beach. Florida 33060 13 EFTA01122258 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 EFTA01122259 COMPOSITE EXHIBIT A 15 EFTA01122260 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 EFTA01122261 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." 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 EFTA01122262 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 Epstcin'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 EFTA01122263 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. Epstein also enlisted his staff in the predatory activity, and fou Lesley Groff, and efigured 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. lie 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 EFTA01122264 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 52,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters such 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 "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 EFTA01122265 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 a