EFTA00599855.pdf

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 CASE NUNN& e4 ays. CML ACTION SUMMONS U DISTRICTS (b) Form for Personal Service on a Natural Person 14021348CAO ❑ OTHER PLAINTIFF(' VS. DEFENDANT(' CLOCK Rd JEAN-LUC BRUNEL JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG 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 I Aisremeuk,-Wrint) ciiee 4-2. * ' se-ret 4:t JEFFREY EPSTEIN 358 El Bab Way On Bead% FL 33480.730 -a i siti-tratt VAC I 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 the attsUrd complaint with the dere of Um court A phone CM .40 not pulsar./ Tax written response, ectucling the came number Oven 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 d on tint you may lose the case. and your wafts. money arc pr party may Orrearier be taken without further swig from the Coin NOM 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 anal set Ore legal ad offal fisted in an %am V004 If you diode to fib a written nreorna rase( at me sn out fie your erten reSCOnScr wdh Me Clerk of Me Cast. r ebo mail a lake a arm of your tendon /spacebar. 'Planter Attorney named holow. The rad& location of dm ▪ ai the Dade Coady Cowthouse. The address for the . act kicatcos are fisted tem for your ra DADS COUNTY COURT LOCAnOtes ®be, Ow* Cass". e61 Ross ,33 O.1.amth CM CC (30) O .1mM On Atoka Comm 1/31 SERVICE Noma 103 Room 100 73 MS Fisja seed sem mw a Assn Isles Room, 131W. lam,. •W.1, 1213C aria. IWO. 32142 Mei Moo newt nonce um ElRes Yam Wei Oman Can Os) 200 O care caw Ousts Cod psi Arm 100 0 Seat Deis Amass Csalm Del Ross Om 1130 wastimagol A.w.ie 3103 Pees Os Ise NI lona ON 211 SIRS Masi lack Fiona. Iii Ca0 a RIOS 33134 away "Isla IMO I 11msh Min (21) Room 100 11 Ent 611•Sbeel 1.114•04. Flo," 330111 PlalrelPlairtiff Attorney Addis: JOE IfTONE 821 M. STH STREET, POMPANO BEACH. FL 33080 Florita Bar No. 203882 HARVEY RUMN VERA snicsitr fr.ai 0920,7N CLEM( OF COURTS DEPUTY CLERK AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost 1 certain assistance. Please contact the Eleventh Jud al Circuit it o the provision of ADA Coordinator, olio 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 CONDADO DE MIAMI-GADE LA FLORIDA o EN EL TRIBUNAL DEL CONDADO EN Y PARA CL CONDADO MLAMI-DADE, LA FLORIDA DIVIMOti NUMERO DE CASO EMPLAZAM/ENTO DE ACCION CML 0 MAL (b) NOTIFICAC1ON PERSONAL A PERSONA NATURAL l] OMA DEMANDANTE(S) VS. DEMANDADO(' 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 peulrla 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 Roos 133 105) D Jota Ca Ca OOI n la Ca AS Cas. (731 eta~ ~te all 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 Card am Ca mn Ct5) L. 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 FECHA 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." CIWCT 070Rer 11111 IffiabeddrecamnitabioNdernalerli.ceni EFTA00599856  0 AU TRIBUNAL DU ONZEME ARRONDISSEMENT JUDICIAFtE DANS ET POUR MIAMI DADE FLORIDE. O AU TRIBUNAL DE JUGEMENT ETPOUR LE DEPARTENT DE MIAM-CADE. FLORIDE DIVISION NUMERO DE CAS CONVOCARION a ACTION CMLE 0 CMLE (b) LIVRAI ON PERSONNELLE A UNE PERSONNE 0 AUTRE PLAINTE() VS. CONTRE ACCUS3) HEURE IN A (AUX) ACCUSER) 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 Na issant 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 devocal. 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 asat s avoca t) =Mn ci la votre avec le Grollim du Tribunal. para du bureau du Greffer a Dade County Coulthixae,Illitee dg u Innment ira 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 n Noah Ose Sale CAMilur. Haie na nu SoM 1 Ream34 Rem lea ROM In Rem lee /3 Win ni stn. Pa t 544el W4 2/ Menue ISSU Navre fa. t tint ern Sena see, see,pow cola art Rats me New mer new' 'bru 231p 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» Adresse. 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 DATE ON: HARVEY RUVIN PAR Greffier do Tribunal COPIE 13fflefER AMONT ACT DE 1990 POUR AMEWCAINS HANDICAPES AVIS DE ADA r "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 i n 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 EPOU PAIAPSDADC COUNI Y. FLORIDA 0 MAN TRIENNAL E POU TRIBINAL IMAN MUUSDADE COUNTY. FLORIDA. DIVIZTON NIMEWO nA KONVOKASYON POU KA SML U SML (b) DEUVRE PERSONELAIAN BAY VON NIOUN 0 LOT PLENTIFII) VS. KONT MUA) LE ADRES: Eagarl 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 peduIM 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 LI 1001•M Olottla f2t) Ro= 133 Rte 103 Rom 100 73 Wall Rader Strie Room 100 Se MW 22 Mitron 1$563 PernreBntl II Fe« 610 Mme 111a fana 1f1! 11mM, Rama 33142 ara MM OMM. Rate 33160 MONO. noble 330,0 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 Railla/Avocat du Plainte Mme nain noka a. Address: 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 flat nase sa il. HARVEY RUVIN DATE: Selerata .leneral TrIblml La BAY: SEKRETE 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. Courthouse Cent«, 175 14W l e Ave., Suite 2702, Miami, FI 33128, Telefan (305) Thomas 7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan 349- ou paret nan tribunal la, oubyen imedyatman M ou ou gen randevou pou resevwa mwens ke 7 jou pou ou paret nan tribunal la; si ou gen notiftkasy on sa a si o s gen pale, rele 711." difilcilte pou ou tende oubyen altrat. 070 Mer 11n1 met RØ se« rruneelaasteSene n 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 elMX Or kes• Sim 0c/ 31. 2016 Calm 0 It 2901. !oriellimp 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 gu