📄 Extracted Text (6,233 words)
FilingII 17175578 Electronically Filed 08/15/2014 08:06:39 PM
IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR DADE COUNTY, FLORIDA
CIVIL DIVISION
JEAN-LUC BRUNEI.
Civil Action No.:
Plaintiff,
vs.
TYLER MCDONALD, TYLER
MCDONALD D/B/A/ YI.ORG
Defendants.
VERIFIED COMPLAINT FOR EOUITABI,E RELIEF AND DAMAGES
COMES NOW the Plaintiff, Jean-Luc Brunel, by and through undersigned counsel, and
sues Defendants Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for equitable relief and
defamation, and states as follows:
1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler
McDonald d/b/a Yi.Org do business in Dade County, and Plaintiff Jean-Luc Brunel resides in
Dade County, Florida.
2. Florida Statute 48.193(1)(aX1) ("long-ann") authorizes service on both out-of-state
Defendants.
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 DEFENDANTS
4. Plaintiff Jean-Luc Brunel ("Brunel") is the owner of a modeling agency known as "MC2
Model Management" ("MC2"). MC2 began operations in October 2005 and has offices in New
York, Miami, and Tel Aviv.
1
EFTA01107970
5. 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.
6. 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 Brunel. (Exhibit attached).
7. These links clearly and falsely associated Brunel 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.
8. 'Mese links have damaged Brunel's reputation as an owner of a well-established
modeling agency with offices in New York and Miami, MC2 Models.
9. These links have also damaged the reputation of Brunel's modeling agency MC2.
10. The combined damage to the reputation to both Brunel and MC2 has resulted in a
significant loss of revenue to MC2, and accordingly, to Brunel.
11. MC2's revenues have fallen to a mere fraction of what they were before the appearance
of the links on Yi.Org.
12. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of
the false and negative information that damaged Brunei's reputation and directly caused damages
to Brunel and MC2.
13. Brunel continues to own and operate MC2 Models to this day, his name still harmed by
the false and negative association with escort services in Florida.
14. Accordingly, Brunel has been severely damaged by information on websites hosted by
2
EFTA01107971
Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and
McDonald.
15. 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 Plaintiff's alleged
involvement with escort services in the state of Florida.
16. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the
name of Brunel with regard to the false and defamatory information disseminated by the
websites they hosted.
17. Bninel continues to own and operate MC2 Models to this day, his name never having
been cleared from the negative information disseminated by Defendants McDonald d/b/a Yi.Org
and McDonald.
18. Brunel has been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and
McDonald, and has accordingly retained undersigned counsel to represent him in this matter,
and is obligated to pay counsel a reasonable fee for his services.
COUNT I — EOUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE
AGAINST MCDONALD AND MCDONAI,D D/B/A YLORG
19. The allegations contained in paragraphs 1 through 18 above are re-alleged and
incorporated herein by reference.
20. Brunel, 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.
21. Brunel has 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.
22. Accordingly, Brunel seeks to become whole by the payment of damages by both
Defendants to compensate him for his losses.
3
EFTA01107972
WHEREFORE, PLAINTIFF requests judgment against DEFENDANTS as follows:
A. I)amages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
COUNT II - DEFAMATION AGAINST PLAINTIFF BY MCDO NA LH AND
MCDONALD D/B/A YLORC
23. The allegations contained in paragraphs I through 22 above are re-alleged and
incorporated herein by reference.
24. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published,
false statements about Brunel using their domain hosting service.
25. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the
statements about Brunel were false.
26. These published statements were read by the internet users who viewed the false
statements.
27. Plaintiff's business reputation was severely damaged as a result.
WHEREFORE, PLAINTIFF requests 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 III - EQUITABLE, RELIEF FOR REPAIR OF BUSINESS REPUTATION
28. The allegations contained in paragraphs 1 through 27 above are re-alleged and
incorporated herein by reference.
29. Brunel has also suffered a significant loss of his own business reputation and a loss of his
agency MC2's business reputation as a direct result of the actions of Defendants McDonald d/b/a
Yi.Org and McDonald.
EFTA01107973
30. Brunel has no adequate legal remedy to make him whole as a result of the damages
suffered in the form of lost business reputation due to the actions of both Defendants.
31. Accordingly, Bnmel seeks to restore his business reputation, and that of MC2, by the
payment of damages by both Defendants to compensate him for his loss of reputation.
WHEREFORE, PLAINTIFF requests 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 Moue
Joe Titone
Attorney
FL BAR #: 203882
621 S.E. 5th Street
Pom ano Beach Florida 33060
EFTA01107974
VERIFICATION
STATE OF FLORIDA
COUNTY oW/Ase pdee
JEAN-LUC BRUNEL, being duly sworn according to law, upon his oath, deposes and says:
I have read the foregoing complaint and all the allegations contained the in. All such
allegations are true based upon my personal knowledge, informatioq and belief.
Sworn and subscribed to before me this day ofitide...il-r- 2014.
MOO VALIMIAP111
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EFTA01107975
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7
EFTA01107976
•
3, m.
Re: Case number 14021348CA01
-
rrl
Dear Jean-Luc Brunel,
In response to your affidavit,
yi.org is a domain hosting provider. yi.org does not produce any content of it's own, nig does
it host any content. It only provides DNS lookup -- translating hostnames to P addresses. it is
used for free DNS hosting by hobbyists, soccer teams, police stations, India musicians, and,
unfortunately, sometimes abusive spammers and hackers. When a hacker or spammer is
identified, their account is disabled and sometimes their information is forwarded to the
authorities.
Neither yi.org or Tyler MacDonald had any Involvement with the content that you found on
google. Al that yi.org provided was the registration of the hostnames. For example, from your
photo I can identify the hostname 'escorts-in-washbum.yi.orgi. The service yi.org provides, is to
translate that to "66.71.253.78'. Nothing more.
Therefore, I am unable to take the offensive content down. Al I can do Is turn off the abusive
account, which I have done. However, if you go to http://66.71.253.78/ , you will still be connected
to the offender's website (which appears to be fronted by a beading website). I can not turn that
off. The only people who can turn that off are the person who put the content online, or the ISP
that owns 66.71.253.78 (the WHOIS record for that IP has been attached to this letter for your
convelnence).
yi.org has been online for 15 years. in that time, I have taken down hundreds of abusive
accounts upon request. I have checked my email archives, and you never sent me any
notification of this abuse or request that these sites be taken down. If you had done so, you may
have saved us a lot of trouble.
This Is not content I put online. 47 U.S.C. § 230 (c) (1). I will be holding you responsible
for any costs that I incur responding to your invalid claim. At the moment, that will Just be postage
to reply to your claim, which I will bill to your lawyer. If you take it any further, you will be billed for
time and inconvenience (both my lawyer's and mine), travel and lodging in Florida, etc as well.
EFTA01107977
Here Is the Information that I have on the abusive account
in question (the registrant
of "escorts-In-washbum.yi.org"):
Email address: gplithrmOstonallsam - Googie will provid
e law enforcement with this
account's registered name, address, where they logged In
from, etc.. with a warrant.
Registered hostnames: 2,760 - This is an unusually high
number. most of my users have
less than 20 registered hostnames.
IP Addresses: 33 - These are where the offender is hostin
g his or her content. Each of the
2,760 hostnames he or she registered maps back to one of
these 33 IP addresses.
I am disabling all hosts registered to the account l'dpks
hrm4,[email protected] now. it may take
up to 24 hours for the changes to take effect globally. If you have
any other questions or
concerns, let me know. Please confirm receipt of this message
and your intentions with regards
to this civil suit.
Thanks,
(Attached on following pages: List of IP addresses used by offend
ing account, and WHOLS
record for "escorts-in-washbum.yi.orn.
EFTA01107978
Active IP's for this account as of September 17th, 2014, 3:36Phl Pacif
ic:
data
66.71.247.203
66.71.247.204
66.71.247.205
66.71.247.206
66.71.253.74
66.71.253.75
66.71.253.76
66.71.253.77
66.71.253.78
74.86.202.94
74.86.202.95
75.126.136.28
75.126.136.29
75.126.136.30
75.126.136.31
74.86.196.248
74.86.196.249
74.86.196.250
74.86.196.251
74.86.202.88
74.86.202.89
74.86.202.90
74.86.202.91
74.86.202.93
74.86.202.92
67.228.190.104
67.228.190.105
67.228.190.106
67.228.190.107
67.228.13.240
67.228.13.241
67.228.13.242
67.228.13.243
+ +
EFTA01107979
WHOIS record for 66.71.263.78 (IP for "escorte-In-washbum.yl.org"):
f
# AKIN WHOIS data and services are subject to the Terms of Use
# available at: https://www.arin.net/whois_tou.html
If you see inaccuracies in the results, please report at
# http://www.arin.net/public/whoisinaccuracy/index.xhtml
# The following results may also be obtained via:
http://whois.arin.net/rest/nets;g=66.71.253.787showDetails=true&showA
RIN=false&ext=netref2
NetRange: 66.71.240.0 - 66.71.255.255
CIDR: 66.71.240.0/20
OriginAS: AS14141
NetName: WIRESIX
NetNandle: NET-66-71-240-0-1
Parent: NET-66-0-0-0-0
NetType: Direct Allocation
Comment: WNO12-ARIN
RegDate: 2008-01-24
Updated: 2012-03-02
Ref: http://whois.arin.net/rest/net/NET-66-71-240-0-1
OrgName: WireSix, Inc.
Orgld: WIRES-2
Address: 55 Marietta Street SW
Address: Suite 2100
City: Atlanta
StateProv: GA
PostalCode: 30303
Country: US
RegDate: 2007-12-17
Updated: 2010-12-27
Ref: http://whois.arin.net/rest/org/WIRES-2
ReferralServer: rwhois://rwhois.wiresix.com:4321
EFTA01107980
OrgNOCHandle: WN012-ARIN
OrgNOCName: WireSix Network Operations
OrgNOCPhone: +1-678-525-7307
OrgNOCEmail: [email protected]
OrgNOCRef: http://whois.arin.net/rest/poc/WNO12-ARIN
OrgAbuseHandle: WN012-ARIN
OrgAbuseName: WireSix Network Operations
OrgAbusePhone: +1-678-525-7307
OrgAbuseEmail: [email protected]
OrgAbuseRef: http://whois.arin.net/rest/poc/WNO12-ARIN
OrgTechHandle: WNO12-ARIN
OrgTechName: WireSix Network Operations
OrgTechPhone: +1-678-525-7307
OrgTechEmail: [email protected]
OrgTechRef: http://whois.arin.net/rest/poc/WNO12-ARIN
RNOCHandle: WNO12-ARIN
RNOCName: WireSix Network Operations
RNOCPhone: +1-678-525-7307
RNOCEmail: [email protected]
RNOCRef: http://whois.arin.net/rest/poc/WNO12-ARIN
RTechHandle: WNO12-ARIN
RTechName: WireSix Network Operations
RTechPhone: +1-678-525-7307
RTechEmail: [email protected]
RTechRef: http://whois.arin.net/rest/poc/WN012-ARIN
RAbuseHandle: WNO12-ARIN
RAbuseName: WireSix Network Operations
RAbusePhone: +1-678-525-7307
RAbuseEmail: [email protected]
RAbuseRef: http://whois.arin.net/rest/poc/WNO12-ARIN
# ARIN WHOIS data and services are subj
ect to the Terms of Use
it available at: https://www.arin.net/whois_t
ou.html
it
I If you see inaccuracies in the results, plea
se report at
EFTA01107981
http://www.arin.net/public/who
isinaccuracy/indexachtml
Found a referral to rwhois
.wiresix.com:4321.
%rwhois V-1.0,V-1.5:00090h:
00 manage.my-tss.com (Ubersmit
Server V-2.3.0) h RWhols
autharea..66.71.240.0/20
xautharea-,66.71.240.0/20
network:Class-Name:network
network:Auth-Area:66.71.240.0/
20
network:ID:NET-6050.66.71.253.
64/27
network:Network-Name:SECONDARY
network:IP-Network:66.71.253.6
4/27
network:IP-Network-Block:66.71
.253.64 - 66.71.253.95
network:Org-Name:EWDHosting.co
m
network:Street-Address:34 Pea
chtree ST
network:City:Atlanta
network:State:GA
network:Postal-Code:30303
network:Country-Code:US
network:Tech-Contact:MAINT-605
0.66.71.253.64/27
network:Created:20130314144920
000
network:Updated:20140612131823
000
network:Updated-By:ip-admin@ma
nage.my-tss.com
contact:POC-Name:Coloat NOC
contact:POC-Email:tp-admin@man
age.my-tss.com
contact:POC-Phone:2399350520
contact:Tech-Name:Coloat NOC
contact:Tech-Email:ip-admin@ma
nage.my-tss.com
contact:Tech-Phone:2399350520
contact:Abuse-Name:Coloat
NOC
contact:Abuse-Email:noc@coloat
.com
%ok
EFTA01107982
----E IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL aRcurr IN AND FOR
IRAMI-DADE COUNTY, FLORIDA.
Il IN THE COUNTY COURT IN AND FOR SALAMI
-DADE COUNTY, FLORIDA.
DIVISION
CIVIL ACTION SIMMONS CASE NUMBER
CIVIL
(b) Form for Personal Service on a Natural Person
14021348CA01
O OTHER
PLAINTIFF(S) VS. DEFENDANT(S)
CLOCK IN
JEAN-LUC BRUNEI.
TYLER MCDONALD.
TYLER MCDONALD D/B/A
YI.ORG
THE STATE OF FLORIDA:TO EACH MIFF OF Ty£ STATE, YOU ARE CONSAM40CD lo
serve Ifils Simmons one a copy of the Canfield
Ns tan eon deindent SI
TO Didendwi(s):
Address:
Tyler MCDoneld 2708157th Avenue SE, Snohomish, WA 98290
NeCtilAtli
A leveret has been Bed against you. You have 20 or/
Ida days after this summons b envied on you to
Dawned corrnsdnt with the desk of this court A phone Be a "e'en response to the
cal wIl not protect Ku Tar written respons
above and the names of the patter mtat be SW e. Include:at the case nunber gMn
If yew want he cart to hear your Ode of the
0me, you may lose the case. and your wages, money case. If you do not ore your response on
and property may thereafter be taken without taller
we Oater legs nX8granall. ww* tom the Court. There
You may slot to owl an attorney right Sway. If you do not know an attorney
sante or a legal ald oleos (Med In the , you may cal an attorney mien*
prow Wok).
if you chop,. to fle • warren response yourself
, if the same time you Se your whin response with
mail or take a copy of the Clerk of the Court, you must also
written response to the ThentiftPtentlfhe Morna
at me Dodo County y rind below. The central lociellon of the Clerk's
. The address fix the courenee ard branch office le
locedcos are listed beiow for yaw convenience:
DARE COUNTY COURT LOCATIOSIII
'..; Oat Curb Carta (CM • 22410 Caleb Cott am
Room 133 • ?lot Cele as Cate( c2.3)
Room 103 Roca 103 SERVICE
73 W881Pea snug 5103 NW 22 Awns
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Mardil/Platrallf Attorney Address:
JOE TTTONE
821 S.E. 5TH STREET, POMPANO BEACH,
FL 33080
Florida Bar No. 203882
HARVEY RUM* iiF,CTOR pupo DATE ON:
BY:
CLERK OF COURTS
DEPtiTY Pak
WW1 % Ii ithsi
AMERICANS WITH DISABILITIES ACT OF 1990
ADNOTICE •
"If you are a person with a disability who need s
participate in this proceeding, you are entitled, at any acco mmo datio n in orde r to
certain assistance. Please contact the Eleventh JudicIal no cost to you, to the prov ision of
Lawson E. Thomas Courthouse Center, 175 NW Circuit Court's MIA Coordinator,
Telephone (305) 349-7175; TDD (305) 349-7174, Far 1 Ave., Suite 2702 Miami, FL 33128,
your scheduled court appearance, or immediately upon (305) 349-7355 at least 7 days before
time before the scheduled appearance is less than 7 receiving this notification if the
impaired, call 711." days ; if you are hearing or voice
CLK/C7. 070 Rev. It/11
Clerk's rob sakes& wortmlin1-026818rtcom
EFTA01107983
*it** DUPLICATE Ok 4* 4*
Clerk's Office: Miami Dade Counter Fl
Entered: 8/26/2014 12:54 PM HOUPO
Office: CIVN Batcht 159292 Trans: 4
Rot.: 3380005 Civil Circuit Fee
Acctt 14021348CA01
3139 Summons Issue Fee $20.0C
Check 4366 Ck Amount = $20.00
.1*-3EN DUPLICATE titen
EFTA01107984
Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM
IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR DADE COUNTY, FLORIDA
CIVIL DIVISION
JEAN-LUC BRUNEL, individually,
and MC2 MODEL &
TALENT MIAMI, LLC
Civil Action No.: 14-21348 CA 01
Plaintiffs,
vs.
JEFFREY EPSTEIN,
TYLER MCDONALD, TYLER
MCDONALD D/B/A/ YI.ORG
Defendants.
AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND
DAMAGES
COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami, LLC, by
and through undersigned counsel, and sues Defendants Jeffrey Epstein, Tyler McDonald, and
Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable reliefand defamation, and states as
follows:
1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler
McDonald d/b/a Yi.Org do business in Dade County, Plaintiff Jean-Luc Brunel resides in Dade
County, Florida, and Plaintiff MC2 Model & Talent Miami, LLC, has an office in Dade County.
The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County,
Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there.
Florida Statute 47.011.
2. Florida Statute 48.193(1)(aXI) ("long-arm") authorizes service on both out-of-state
Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org).
1
EFTA01107985
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 8c 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
EFTA01107986
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 IS, 2014. This amply demonstrates that
Epstein's intentional & illegal activities continue to cost Plaintiffs' business income. (Exhibit 13
attached).
13. A third example of a lost business relationship can be found in an e-mail dated October
17, 2014 (Exhibit C attached). The director of the 1 Mother Agency, Vladmir Yudashkin, states
that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs' will force
her into illegal activities. The model bases her fears upon the stories on the internet falsely
implicating Plaintiffs as being involved with illegal activities with young models. This is
3
EFTA01107987
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). Manucla Martinez of Mega Partners, a Brazilian
modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff
MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs .
This reference is clearly to the false allegations online regarding sex trafficking that were based
in the false link between Epstein and Plaintiffs.
15. A fifth example of a lost business relationship can be found in an e-mail dated
on Plaintiff's behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agencc
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 Bninel that he
cannot sign any new models for Plaintiff Brunet'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
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that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems.
I thwever, because of the false Internet trafficking links between Plaintiffs and Epstein, Fox states
that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up.
18. Before the false links between Plaintiff and Epstein surfaced, Plaintiff Brunel was
earning a great deal of revenue from MC2 Miami.
19. The false links between Plaintiffs and Epstein began to surface online in about 2005-
2006. Then, in 2006, Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs
then made an investment totaling one-million dollars with Elite Paris, to start a company.
20. Next, Plaintiff Brunel started the company, "E Management", to work with Elite Models
in Paris, Plaintiff had to close it almost immediately, because Elite didn't send any models to
Plaintiff MC2 for fear of being linked to Epstein.
21. Because the false links between Plaintiffs and Epstein began to gain strength online, Elite
Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment
of one-million dollars because of this loss of business.
22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar
loss.
23. Additionally, a former financial controller of MC2, 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
o f the website Jezebel (Composite Exhibit A, p.2-7).
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25. The deposition testimony o 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 Brunet's MC2 modeling business. Plaintiff Brunel
has been forced to cancel his latest visa application as a result of the delays. (Exhibit J —
Composite — Visa Does).
27. As a result of the notoriety and tremendous publicity surrounding Epstein's criminal
charges, and the media linkage of Epstein to Plaintiffs regarding illegal activities, Plaintiffs lost a
tremendous amount of business and revenue.
28. Plaintiff Brunel's agency MC2 has lost millions of dollars in revenue since the media
revealed that Plaintiffs and Epstein were associated. In fact, Plaintiff MC2 was worth millions of
dollars; now, due to the illegal actions of Epstein, MC2 is almost worthless.
29. At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the
Epstein's illegal activities.
30. As a result of Epstein's illegal activities and his association with Plaintiffs, Plaintiffs
continue to lose money and suffer damages to this day. (Exhibit K attached, Jeff Fuller email,
11-12-14).
31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to
what it was once worth — money that the Plaintiff Brunel does not have.
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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 Bruners deposition.
34. As a direct result of Plaintiff Bninefs travels, his deposition was delayed twice. When it
was finally scheduled for November 2009, Plaintiff Bninel 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 ofjustice 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 Bninel was under tremendous
psychological pressure throughout this period of time.
37. This psychological pressure resulted in Plaintiff Bninel 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.
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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 arc obligated to pay counsel a
reasonable fee for his services.
FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER
MCDONALD D/B/A VI.ORG
45. Defendant Tyler McDonald ("McDonald") is the owner/operator of Yi.Org and also does
business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org").
Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service
based in Vancouver, British Columbia, Canada.
46. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting
websites that contained hyperlinks that contained blatantly false and extremely disparaging
information about Plaintiffs. (Exhibit Q attached - hyperlink scrcenshot).
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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 Brunt'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 wcbsitcs hosted
by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and
McDonald.
55. The information disseminated by the websites hosted by Defendants McDonald d/b/a
Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged
involvement with escort services in the state of Florida.
56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the
names of Plaintiffs with regard to the false and defamatory information disseminated by the
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websites they hosted.
57. Plaintiffs continue to do business to this day, their names never having been cleared from
the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald.
58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and
McDonald, and have accordingly retained undersigned counsel to represent him in this matter,
and 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 arc 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 - EOUITY - AS TO DEFENDANT
JEFFREY EPSTEIN
63. The allegations contained in paragraphs 1 through 44 above are re-alleged and
incorporated herein by reference.
ℹ️ Document Details
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fd3e9a107b15457e802338f002d78c19913340514ed0f28f3b4ae141209229dd
Bates Number
EFTA01107970
Dataset
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Pages
29
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