Jeffrey Epstein & Jean‑Luc Brunel sued for alleged $1 M payment, obstruction of justice, and defamation – links to high‑profile figures

El IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. III IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. DIVISION 2 CIVIL IN DISTRICTS • OTHER CIVIL ACTION SUMMONS (b) Form for Personal Service on a Natural Person CASE NUMBER 14021348CA01 PLAINTIFF(S) JEAN-LUC BRUNEL VS. DEFENDANT(S) JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A YI.ORG CLOCK IN THE STATE OF FLORIDA:TO EACH SHERIFF OF THE STATE, YOU ARE COMMANDED to serve this Summons and a copy of the Cotr4taint this lawsuit on defendant: in To Defendant(s): JEFFREY EPSTEIN Address: -1.,*,---,; •Ef-i:e • I-f-2- -(Jble,4- *(40,,,t4t-f-AIP' 358 El Brilio Way Palm Beach, FL 33480-4730 .1"cl$F1..31 IMPORTANT A lawsuit has been tiled against you. You have 20 calendar days after this summons is served on you to file a written response to attached complaint with the derk of this courL A phone call will not protect you.Yrxr written response, including the cose number given above and the names of the parties must be filed if you want the CODA to hear your side of the C.8541. If you de not filer your resporM time, you may lose the case, and your wages, money and properly may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney, you may call an attorney reierral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response with the Clerk of the Court you must mail or take a copy of your written response to the "P(aintiff/Plaintiffs Attorney' named below. The central location of the Clerk's office at the Dade County Courthouse. The address for the courthouse, and branch locations are listed below for your comenience: DADE COUNTY COURT LOCATIONS the on also is EiDade County Couitbouss (06) I Joseph Caleb Cantle- (20) 0 Notth Dade Justice Cordes (23) Room 133 Room 103 Room 100 73 Watt Hagler Street 5400 NW 22 Avenue 15555 Biscayne BM/. Miami, Florida 33130 Warm, Florida 33142 North allarri Beach. Flottda 33160 ElMimi Beach District Court (24) In Corti Gabtas District Court (25) II South Dade Justice Center (26) Room 200 Room 100 Room 1200 1130 Washington Amosie 3100 Pono: De Lem BIM 10710 SW 211 Stnied Miami Beach, Florida 33133 Coral Gables, Floricia 23134 WA* Honda 331/10 II Hialeah District (21) Room 100 11 East 61h areal Hialeah. Florida 33010 SERVICE Plaintiff/Plaintiff Attorney JOE TITONE Florida Bar No. 203882 Address: 621 S.E. 5TH STREET, POMPANO BEACH, FL 33060 HARVEY RUVIN CLERK OF COURTS VIVRA Sikilumt: ir BY: , DATE ON: 1E6 0 0 2015 DEPUTY CLERK AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order participate in this proceeding, you are entitled, at no cost to you, to the provision certain assistance. Please contact the Eleventh Judicial Circuit Court's ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification time before the scheduled appearance is less than 7 days; if you are hearing or impaired, call 711." to of if the voice _________ CLIC/CT. 070 Rev. 11111 Cleric's limb address: meat. D EN LA CORTE DE CIRCUIT° DEL UNDECIMO CIRCUIT° JUDICIAL EN Y PARA EL CONDADO DE MIAMI-DADE, LA FLORIDA. 0 EN EL TRIBUNAL DEL CONDADO EN Y PARA EL CONDADO MIAMI-DADE, LA FLORIDA. DIVISION DI CIVIL L _ OTRA EMPLAZAMIENTO DE ACCION CIVIL (b) NOTIFICACION PERSONAL A PERSONA NATURAL NUMERO DE CASO DEMANDANTE(S) VS. DEMANDADO(S) HORA A Demandado(s): Direccion: listed ha sido demanded° legalmente. Tbene 20 dias, escrito, y presentarla ante este tribunal. Una LIamada presenter SU respuesta por esaito, induyendo el numero tiempo, pudiese peeler el caso pordria ser despojado Existen otros regtisitos legates. Si lo desea. poade una de (as oficinas de asistencia legal (Legal Aid Is guia telefonica. SI desea responder a la dementia por su cueeta, al o entregar en la mane una copia de SU respuesta a Demandante) y presenter su contestadon a la domande edificio de la Code del Candado de Dade. La direccion LOCAL1DAD CI Dade County Courthouse (05) 0 Joaeph Caleb Room 133 Roue 103 73 Weal Flagler Street 540 NW 22 hitiorni, Rcrioa 3313D Miami, Florida 1:1 kbarrd Eleach Cestrict Court (24) 0 c.aki oatkii Room 200 Room 100 1130 Washington Avenue 3100 Ponce MAarn1 Beath, Florida 33139 Cm( Galslea. IMPORTANTE contester la demanda adj crinsidere su defense, Sl usted no contests la denanda sin previo aviso del a un abogado, puede Referral Service) que aparIcen debera usted envier ofir (Demandante o Ahmed° la Mina del Secretario elta para su convenienci2: El Walsall Dtatrict (21) Room 100 11 Bost 6th Street Hialeah, Hondo 33010 nia, por debe a tribunal. Ikamar a en correo del en el cordados a partir del recibo de este notification, para leiefonica no lo protegera. Si usted desea que el tribunal del caso y los noinbres de Las partes irderesadas. de sus ingresos y propiedades, o privado de sus denachos, usted consulter a un abogado inmediatamente. Si no conoce Office) o tin servicio de referenda de abogados (Attorney misrno liampo en que presents SU respuesta ante el tribunal, la persona denominada at)* como 'Plaintiff/Plaintiffs Attorney" al Secretario del Juzgado. La tibial:ion central de de ta Code, y de (as sucursales aparecen en la Lists siguiente DE LOS 71IBUNALES DEL CONDADO DE DADE Career (20) 0 kWh Dade Judio5 Clatter (23) Room 100 Avenue 15555 Biscayne Elhod. 33142 North Marra Beach, Floeda 33150 District Cowl as 0 South Dade Justine Center (25) Room 1200 De Lem PM. 10710 SW 211 Street Fi011112 33134 Mama, Florida 331E19 Dernandante c Abogado del Demandante Numen3 del Colegio de Abogados: Direccion: EL ESTADO DE LA FLORIDA: A cada alguacil del Estado: Se le ordena que hagen entrega de esta nolificacion y u copia de la demanda en este pied° at tlemandatio(s) mencionada arriba. la HARVEY RUVIN Secreted° del Tribunal del Condado POR: FECHA GornoSecretario Adjunto Ley para Estadounidenses con Incapacidades "Si usted es una persona minusvalida gue necesita bacer arreglos para poder participar en este proceso, usted tiene derecho, sin gasto alguno, a que se le provea cierta apda. Por favor pong_ase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial uhicado en el Lawson E. Thomas Courthouse Center, 175 NW 1st Ave. 2702, Miami Fl 33128, Telefonos (305)349-7175; TDD (305) 349-7174, Fax (305) 349-7355 por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales; inmediatamente despues de recibir esta notificacion si el tiempo antes comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la voz, llame al 711." Sala o de la CLK/CT. 070 Rev 11111 Clerk'es web cellintss: Ninny. U AU TRIBUNAL DU ONZIEME ARRONDISSEMENT JUDICIARE DANS ET POUR MIAMI-DADE, FLORIDE. 0 AU TRIBUNAL DE JUGEMENT Er POUR LE DEPARTENT DE MIAMI-DADE, FLORI DE. DIVISION CI CIVILE D AUTRE CONVOCARION (b) LIVRAI ON PERSONNELLE Cr ACTION CIVILE A UNE PERSONNE NUMERO DE CAS PLAINTE(S) VS. CONTRE ACCUSE(S) HEURE IN A (AUX) ACCUSE(S): ADRESSE: Des poursuites judiciaires ont ete enterprises contra citation pour deposer use response mite a La plainte protegee. Vous etas obliges de deposer votre response nommees ici, si VDUS souhailez qua ,:a tribunal entende risquez de perdre is cause sins' que vote sataire, tribunal. II y a d'autres obligations juridiques at vous vous pourriez telephoner a tin service reference cfavocats Si votts choisissez de deposer VOUS-Mellie UM reponse expedier une copte de votre reponse ecrite au •PlairtifiPtairdirs reponse avec le Grafter du Tribunal. L'adresse l'adresse des succursales sort dans ci-dessous pour 0 Dade County Courthouse (05) 0 Joseph Czech Room 133 Room 103 73 Weal Flaglet Street 5400 NW 22 Miami, Florida 33130 Warr& Ficrida El ktierni Beech Dtstrict Ccurt (24) 0 Corot Gables Room 200 Room 100 1130 Washington AVellie 3100 Ponce SAWN Beach. Florida 33139 CCIAI Gebtee, IMPORTANT la data de rassignation de est insoffisant pour ci-dessus at du nom des ecrite dans le relai requiS. suite, aucun preavis ulterle vous no connaissez pas d'• rannuaire de telephones). cette formate, faire parvCnir ci-dessous at emegistrei L'adresse du trib 0 Htelesh District (21) Room 100 11 East 6th Street Hialeah, Flodde 33010 cede vous 3arties VOUS ur du vocal, ou votre nat,el VOUS. Vous ci-jointe ecrite, vote votre argent, pouvez requerir ou a ecrite, centrale du wire convenance avez 20 jours consecutifs a partir a de aupres de 03 Irthurtal. Ull SkT1010 coup de telephone ac mention du nurnero de dossier muse. Si vous no deposez pas aotre reponse at vos biens peuvent etre saisIs par La les services immedlats d'un avocet. Si tin bureau dessistance juridique (frgurard a it VOUS faudea egaternent, en memo temps qua Attorney (PlaignaM ou a son avocet) nomrne bureau du Craftier est le Dade County Courthouse. DES IRIBLINAUX EN DADE 0 North Dade Justice Center (23) Room 100 15.53 Biscayne Btvd. North Wand Broth, Florida 33160 (25) 0 South Dade .histice Center (26) Room 1200 10710 SW 211 Steel Wane, Ronde 33189 ADRESSES Cotter (20) Avenue 33142 District Court Be tem Stmt. Florida 33134 Plainte/Avocat du Plainte Numero de barreau de la Floride: Adresse: LTAT DE LA FLORIDE A chaque sherff de retat vous etes oblige de presenter cette citation et une photocpie de la plainte ce document sur rarnuse (e) ci-desus. ie HARVEY RUVIN Greffier de Tribunal ' PAR: DATE ON: OOMVE GREFFER Af1101NE .. ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE l' ADA "Si vous etes une personne handic,apee qui a besoin d'accommodement pour pouvoir participer a cette procedure, vous avez le droit, sans aucun coot, d'avoir de l'aide a disposition. S'il vous plait contacter le Coordinateur de l'ADA du Tribunal de l'OnYieme Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW 1.3t Ave. Suite Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 moms 7 jours avant la date de comparution au tribunal, oubien immediatement avoir recu cet avis si la date avant la comparution est moms de 7 jours; si vous avez incapacite pour entendre ou parler, appelez le 711." votre 2702, au apres une CLKJCT. 070 Rev. 11/11 Cient's eth address: anew erk.com 0 NAN TRIBUNAL ONZYEM AWONDISMAN JIDISYE NAN E POU MIAMI-DADE COUNTY, FLORIDA. 0 NAN TRIBINAL E POU TRIBINAL NAN MIAMI-DADE COUNTY, FLORIDA. DIVIZYON El SIV1L 0 LOT KONVOKASYON POU KA SIVIL (b) DELIVRE PERSONELMAN BAY YON DAMN NIMEWO KA PLENTIF(S) VS. KONT AKIZE(S) LE AKIZE: ADRES: Yo entre yon aksyon kont oumeum. Ou genyen 20 jou grefie tribunal-sa, yon reponce pa ecri attache avec plent4a. ecrifo ou mete numero ka-a ki sou tet pagela avec nom position-0u cou ka-a. Si ou pa enregistre reponce-ou ou capab pedu l'agen ou ak byen ou. Genyen lot demande. avoka, ou ka rele sevis id rekomande evoke, ou biro ede Si ou shoisi voye yon reponce pa ecri oumenm, ou supose pa ecri pou avoka pleyan ou pleyan-yo ke non-li ama-a Tribinal. Adres santrat biwo Sekrete a se Dade County pou ou kaiwenn ye alez: MIRES TRIB1NAL 0 owe ccuity C,osethouse (05) CI Joseph Caleb Center (20) Room 133 Roam 103 73 West Ftagler Street 5400 NW 22 Avenue Warm, Ronda 33130 Ward, Florida 33142 Ell Miami Beech Distri:1 Cool (24) LI ower Saida* Dielnct Court Room 200 Room 100 1130 Washington Avenue 3100 Porto% De Loon 131,41 Mani Bomb, Floada 33135 Coral Gablex Florida 33134 En pou enregistre cevan Se yen repenite si ou vie ke tribunal-la la pa enounce-ou en de suit. Si ou pa !oriel on pote on copi response ki localize nan avek lot tribinal yo nan lis ki CI lilal DtstOot (21) Roam 100 11 Eest 6th Sliest 1-11sioa1i. Rod& 33010 pa kende yen, yen --krete .nba a kalandriye apres ou recevoi sornasyon-an Yon apei pa teleran ka kapab protege-ou. moune-yo ki sou papie-sa oblige ecri a l'heure ou capab pedu ke-a san tribunal Ou ka besoin telefone yon avoka tout legal (ki nun lis liv telefone). en mem Ian poste en mem tan poste et enregistre reponce-la nan tribunal-la Courthouse. Adres tribinal la, ak adres NAN DADE COUNTY El 1-4.111 Dade Justtos Genie/ (23) Room 100 15555 Btscayne Blvd. North tani Reach. Fltrittl 33160 (25) 0 South Dade Justice Center (76) Room 1200 10710 SW 21) Street Welt Ronda 33189 Plainta/Avocat du Plainie Numero de barreau de la Floride: Nimewo manm avoka a. Address: ETA FLORIDA: Pou Chak nan eta a yo odone ou pou bay akize a (yo), non I ekri anwo a, manda sa a ak yon kopi yo pate an pwose sa a. HARVEY RUVIN Sekrete Jenemi Tribinal La BAY: DATE: SEKRETE LWA 1990 POU AMERIKEN KI ENFINI ANONS POU ANIERIKEN KI ENFINI "Si out se yon moun ki enfim e on bezwen akomodasyon pou on patisipe nan pwosei sa a, on gen dwa pou yo ba ou kek ed san on pa gen pou on peye. Silvouple ko 1 takte KowOdinate ADA pou Tribinal Onzyem Distrik Jidisye a nan: Lawson E. To omas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, Fl 33128, Telefen (305 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan on gen randevo pou on paret nan tribunal la, oubyen imedyatman le on resevwa notifikasyon sa a si o gen mwens ke 7 jou pou ou paret nan tribunal la; si on gen difikilte pou on tande o byen pale, rele 711." CU(/CT. 070 Rev. 11/11 CiefleS web adriress: www.vgp erk.oam 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 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, 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)(1) ("long-arm") authorizes service on both out-of-state Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org). 1 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 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. 11. 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 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 intemet falsely implicating Plaintiffs as being involved with illegal activities with young models. This is 3 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 Plaintiff's 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 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. 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, Maritza Vasquez, 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 Maritza Vasquez). 24. Maritza Vasquez 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 Conchita Sarnoff of the website Jezebel (Composite Exhibit A. p.2-7). 5 25. The deposition testimony of Maritza Vasquez 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 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. 6 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 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 & 0 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 YI.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 screenshot). 8 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 Brunei'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 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 9 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 are 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 1 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 1 through 44 above are re-alleged and incorporated herein by reference. 10 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 COUNT IV — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG 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 YLORG 75. The allegations contained in paragraphs 1 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 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/ YLORG 80. The allegations contained in paragraphs 1 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. Is/ Joe Titone Joe Titone Attorney FL BAR #: 203882 621 S.E. 5th Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) Joetitone708@comcast.net 13 VERIFICATION STATE OF FLORIDA COUNTY OF/f-i/--1-44/ /211.0 JEAN-LUC BRLTNEL, being duly sworn according to law, upon his oath, deposes and says: I have read the foregoing complaint and all the allegations contained therlin. All such allegations are true based upon my personal knowledge, informatio and belief. I (id! JE BRL Sworn and subscribed to before me this / day of4e2z,...,/-r , 2014. PALO VALLAMES Nanny Pal4c - Florkta 1 lir Caren. barn Oc.1 31, an B Coarniala •Eg 211500 4 Scrawl Throw* NSW Navy Mot ps...i.......upeirimpnwepeopmempft NOTARY PUBLIC 6 14 COMPOSITE EXHIBIT A 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 of Justice 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.) • Conchita Sarnoff: 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 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 $1 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." Conchita Sarnqff has developed multimedia communication programs.for Fortune 500 companies and has produced three current-events debate TV 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 17 ,http://www.thedailybeast.com/articles/2010/07/22/ieffrey-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-daily massages, pornographic artwork, and hush money—that's only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive exposé. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-daily massages, pornographic artwork, and hush money—that's only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive expose. 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 Brill° 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. He 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 Nadia Marcinkova, who was referred to in press accounts and police reports as Epstein's live-in "sex slave." A former bookkeeper in the Miami office, who also arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein's private jets. 18 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. - Conchita Sarnoff: 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 four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged. According to police reports and sworn statements in the civil suits, all four women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein's live-in partner, also recruited young girls. Since his 13-month sentence for soliciting prostitution with a minor, Epstein has settled more than a dozen lawsuits brought by underage girls. Seven victims reached a last-minute deal last week, days before a scheduled trial; each received well over $1 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. He was fired, he says, for inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money. He saw an unfamiliar "beater" in the driveway one evening and called 91!. When he left Epstein'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 Unfortunately, he made the offer to an undercover cop, and was subsequently charged with "obstruction of official proceedings" for withholding information that could have advanced the criminal investigation of Epstein—which by that point had been settled in a plea deal. Rodriguez was sentenced to 18 months in federal prison (Epstein was allowed to serve 13 months in the Palm Beach county jail), and now awaits an additional sentence on Aug. 24 in federal court in Miami for transporting firearms, another deal he says he made to pay the bills after he lost his job. In a deposition given for the civil suits, Rodriguez testified that he was instructed to always have $2,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters such as [REDACTED] 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 Marcinkova "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, Model: The Li:5.g). Business of Beatitifid fPnnen. 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 $1 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 Bruners activities, 20 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 agency's 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. Pilot logs obtained in the civil suits show that some of the named plaintiffs were on the flight manifests. Other times, the pilot would just list the other passengers plus "female." Editor's Note: An earlier version of this article misidentified the subject of Craig .Pyes ' investigation and the title of Michael Gross' book. The Daily Beast has corrected the subject and title and regrets the error. Read Conchita Sarnoff's oriuinal report on Epstein. Conchita Sarnqff has developed multimedia communication programs for Fortune 500 companies and has produced three current events debate television programs, The Americas Forum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Heington Post. She is writing a book about child trafficking in America. 21 http://fashioncopious.typepad.com/fashioncopious/2010/08/mc2-modeling-agency-involved-in-sex- trafficking.html MC2 Modeling Agency Involved In Sex Trafficking August 11,2010 On August 4th Jezebel ran the following story: The Sex-Trafficking Model Scout. 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, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova '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. The previous paragraph in the story read: and making [speaking of Jeffrey Epstein] frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. 22 http://bettyfokker.wordpress.com/2010/08/20/hes-helping-others-get-away-with-child-sex- trafficking/ He's helping others get away with child-sex trafficking Posted on August 20, 2010 by Betty Fokker Let's discuss that billionaire douche-face child-rapist, Jeffrey Epstein for a moment shall we? He's someone who likes to have sex with venerable underage girls, including 12 year old girls who are trafficked into the US under the guise that they will become models. His partner in crime was Jean Luc Brunel, owner and 'talent scout' of the MC2 "modeling agency". Epstein coincidently invested a million bucks in the MC2 ki.€14ie-pefn-Fifig modeling agency and let Brunel use his privet jet. The FBI thinks Epstein has assaulted/molested about 40 or so young girls. So he's going to prison for the rest of his life right? Wrong. When faced with the best defense lawyers money could buy, the prosecutors wimped out and made a plea bargain so light it boggles the mind. This kid-raping bastard only had to please guilty to two MINOR charges and gets a private cell, a cell he gets to leave on a "work release program" by the way. Now, I am not blaming his defense attorneys. They were doing their job and, under our constitution, a festering anus like Epstein has the right to the best attorneys he can afford. I am livid with the prosecuting attorneys. It was their job to do everything in their power to bring this vomit-inducing shit-sack to justice. Instead, they decided to gutlessly pander to his wealth, privilege, and powerful defense team. They rolled over and did everything but send in another kid to give this fucker a hand-job. So this vermin got away with raping 12 year old girls because the prosecuting attorneys couldn't find a single testicle/ovary to share among them. And do you know what their chicken-shit kowtowing to Epstein has wrought? It's opened the door for other child-sex traffickers to get lighter sentences for their crimes too. Why should they have to pay when he didn't? After all, it was just girls they were trafficking for sex with disgusting older males (I refuse to call something like Epstein a "man"; it insults men) ... they weren't harming anything of any value in our culture! I'm a feminist because I think girls & women have value. What a crying, fucking shame there wasn't one feminist in the prosecutors office to go after this monster and punish him. What a pity other hell-spawn might get away with trafficking girls for sex more easily because of the shit- for-brains attorneys who let Epstein get away with his crimes. My eyeballs are melting with rage. Never mind. They aren't melting. It's just tears of helpless and despairing rage against an unjust legal system and the cultural devaluation of women and girls. 23 http://zawkencom/5600294/reeently-freed-sex-offender-jeffrev-enstein-may-face-child- trafficking-charges Recently-Freed Sex Offender Jeffrey Epstein May Face Child Trafficking Charges t•r • 11 t* POtwa- ,kaasemie XFIttr 0:71/1 rg mi..tipiT WV1,1.1 -I -4! Ads by Google Expand Jeffrey Epstein, the billionaire Bill Clinton pal who just left jail after completing a sentence for soliciting sex with a minor, may be headed back soon: The Daily Beast reports that the Justice Department is investigating him for child trafficking. Epstein, famous for being rich, being friends with Bill Clinton, having an egg-shaped penis, and being a vindictive pervert, can't be prosecuted again for the charges he copped to in his plea deal. But according to The Daily Beast's Conchita Sarnoff, new charges might be coming: As we learned in Vanity Fair yesterday, Bill Clinton has spent his post-presidential life...Read more 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. Since there's no statute of limitations for sex-trafficking, and Epstein's predatory adventures apparently date back more than a few years, it's likely there's more women who could come forward. (Apparently some have contacted a lawyer, but nothing's been filed yet.) It's not just Epstein, either—his buddy Jean Luc Brunel, head of the MC2 modeling agency, is also being investigated, and some of the models he represented (many from overseas) may have been enlisted as companions on Epstein's private jet. 24 http://www.huffingtonpost.com/20 I 4/06/03/j e ffrey-e pste in_n_5439407.html MIAMI (AP) — Nearly a decade ago, a wealthy financial guru came under FBI investigation, suspected of sexually abusing dozens of underage girls at his Palm Beach mansion. Then, abruptly, the investigation was dropped and Jeffrey Epstein pleaded guilty to a single state charge of soliciting prostitution. He served just over a year in jail. Now, two women who say they were among his victims have won a precedent-setting appeals court ruling entitling them to see all the documents from the plea bargain discussions between Epstein's high-powered lawyers and federal prosecutors. Their goal: use those tiles to undo the agreement. reopen the investigation and subject Epstein to more charges. The women's lawyers contend Epstein got special treatment because of his wealth and connections. His attorneys deny that. Epstein. 61, made hundreds of millions of dollars managing funds for rich clients. Shortly after his 2008 guilty plea. it came to light that his lawyers had secretly reached a non-prosecution agreement months earlier with the U.S. Justice Department that spared him a potentially heavier punishment. "Our complaint alleges that. prodded by Epstein. the federal prosecutors deliberately concealed the sweetheart plea deal they made with him to avoid public criticism," said Paul Cassell. a University of Utah law professor who is representing the two women. The U.S. attorney's office in Miami would not comment. But the U.S. attorney at the time, R. Alexander Acosta, said in a 2011 letter defending his office that more evidence came to light after Epstein made his deal. "Many victims have spoken out, tiling detailed statements in civil cases seeking damages. Physical evidence has been discovered," Acosta wrote. "Had these additional statements and evidence been known, the outcome may have been different." Epstein has settled lawsuits for undisclosed amounts with many of the women who say they were underage when they were paid for sex. The case represents the first time a federal appeals court has ruled that the Crime Victims' Rights Act of 2004 guarantees victims the right to be informed about the details of how a plea bargain was reached. according to legal experts and lawyers involved in the case. The law marked the culmination of efforts begun in the 1960s to give crime victims more of a say. 25 "I hope that the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach." Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge, sold his Palm Beach home in 2011 and now divides his time between a New York City home, a Caribbean island and an apartment in Paris. according to court documents. He also has a large New Mexico ranch. He donates huge sums each year, particularly toward projects involving new medical treatments and artificial intelligence. His foundation established a Harvard University program that uses mathematics to study evolutionary biology, viruses and disease. According to lawsuits filed by some of his accusers. Epstein relied on assistants to recruit underage girls to give him massages and perform sex acts. They were usually paid about $200. Some girls were notified about the investigation beginning in 2006. But they weren't told about the negotiations with federal prosecutors for at least nine months, despite a requirement in the Crime Victims' Rights Act that they be kept informed. The two women — who were 13 and 14 when the alleged assaults occurred — sued for the files and won. "Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal prosecution do not enjoy a relationship of confidence and trust when they negotiate." the appeals court said. Federal prosecutors have begun turning over the documents. Epstein's attorney. Roy Black, the celebrity lawyer who is also representing Justin Bieber in his DUI and resisting-arrest case in Miami Beach, declined to comment but has asked that the documents be kept from public view, and so far they have been. In a May 23 court filing. Black said that there was no conspiracy between prosecutors and Epstein's team to violate the victims' rights law and that the non-prosecution agreement contained many provisions Epstein strongly opposed. such as registering as a sex offender and agreeing not to contest certain lawsuits. "This was no sweetheart deal by any stretch of the imagination," Black said in court papers. Even if a judge invalidates the plea deal, it will still be up to federal prosecutors to decide what to do. "The court can't force the prosecutors to bring charges," said Matt Alexrod, a former federal prosecutor now in private practice in Washington. 26 http://www.huffingtonpost.com/conehita-s-sarnoff/ehild-trafficking_b_1269748.html Conchita Sarnoff Communications expert Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, nublished "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunelts latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to prevent depositions. "Trawling for 511" underage teenagers to work for his agency. MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: 27 we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a 'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross's 1995 book, describes Bruners activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journal magazine. In that stor‘ "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!" Ford recalls. "But went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." http://jezebel.com/5603638/meet-the-modeling-agent-who-trafficked-underage-girls-for-sex The Sex-Trafficking Model Scout 28 xpand Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a prominent modeling agent and scout. Here's what we know about Jean Luc Brunel. Jeffrey Epstein, you will no doubt recall, is the man who thought ferrying Bill Clinton on his private jet, lawyering up with superstar Alan Dershowitz, and making frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Say you're not as famous or celebrated as Roman Polanski and you want to sexually assault...Read more Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. But as Conchita Sarnoff wrote at The Daily Beast: 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, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova '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.' The FBI investigated Epstein, and identified around 40 underaged victims. Sarnoff reports that the FBI is also investigating MC2 and Brunel for possibly engaging in child sex trafficking. Since pleading guilty to reduced charges of soliciting sex with a minor and serving 13 months of 29 part-time jail, Epstein has become the focus of numerous civil lawsuits from his victims. He has so far settled a dozen. These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper, a number of the girls worked for MC2, the modeling agency owned by Jean Luc Brunel, a longtime acquaintance and frequent guest of Epstein's. Brunel, along with numerous young models, was a frequent passenger on Epstein's private jet, according to flight manifests. The agency owner also allegedly received $1 million from Epstein in 2005, when he founded MC2 with his partner, Jeffrey Fuller; although Fuller and Brunel denied any such payment from the billionaire pervert in 2007, when rumors started swirling, Sarnoff got confirmation from a former bookkeeper at the agency. Whether the money was a secret investment in MC2, or a payment for Brunel's services as a procurer, is unknown. Brunel also visited Epstein in jail. So who is Jean Luc Brunel? Although he did not respond to our interview request, we spoke to a number of people who have worked with his agency. While MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either: MC2 in New York most recently launched the career of Latvian editorial star Ginta Lapina (Brunel "discovered" Lapina via an MC2 scoutina competition for young teens) and currently represents Vogue China covergirl Liu Dan. Worldwide, MC2 represents such stars as Sessilee Lopez in Miami, and top models Candace Swanepoel, Marina Lynchuk, Natalia Chabanenko, and Elisa Sednaoui in Tel Aviv. Brunel isn't involved with the business on a day-to-day basis, although he owns an 85% stake in MC2. Instead, "Right now he does scouting for [the] agency and takes care of the international relations with other agencies," reports one source. Scouts scour the world for un-agented teenaged girls who could make it as models; they work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight — even relative to the almost totally unregulated modeling industry itself. "He travels a lot," says another person who has worked with Brunel. (The company blog refers to Brunel as a "scouting tsunami." and MC2 is fairly well-known for the strength of its international scouting.) Models we spoke to report mostly positive experiences with Brunel — one praised his sense of humor and said he is "lovely to all of his models," and another described him as highly intelligent and cultured, adding, "he knows a lot about the opera and he paints" — although it should be noted that none of the models whom we spoke to had been told of either his connections with Epstein, or his past. And what a past it is. These accounts from Michael Gross' 1995 book Model describe Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karins, now known as Karin Paris: "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karins was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always 30 been on the edge of the system. John Casablancas gets with girls the healthy way. Girls would be with him if he was the butcher. They're with Jean-Luc because he's the boss. Jean-Luc likes drugs and silent rape. It excites him." "I really despise Jean-Luc as a human being for the way he's cheapened the business," says John Casablancas. "There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano...They were very well-known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." It should be noted that aside from being a professional rival, Casablancas, the founder of the agency Elite, was eventually drubbed out of the industry for his own modelizing. How pervy do you have to be for John Casablancas to call you a perv? Pervy enough to drug and rape numerous teenagers, according to 60 Minutes and Diane Sawyer, who investigated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel andJor by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that Brunel and/or his friends had drugged and raped them. Said producer Craig Pyes, "Hundreds of girls were not only harassed, but molested." When Gross interviewed Brunel, this is what he had to say for himself: "You get laid tonight with a model, is that a crime? I don't understand why people go into your personal life, what you do yourself, and to yourself, and they don't look at things that are really important." Since then, Brunel has been involved with a succession of agencies in New York and Paris. Although the 60 Minutes scandal eventually led Eileen Ford to stop working with him, he continued his involvement with Karins. In 1988, when powerhouse agency Next opened its doors, Brunel took an ownership stake. He also "discovered" Christy Turlington when she was 14. MC2 is only his latest venture. Because no criminal charges were ever filed by any of his accusers, and because the industry has a short memory — most models working today weren't even born when Sawyer and Pyes started looking into Brunel's activities — Brunel has been free to continue as he pleases. A French citizen, he even avoided testifying in his friend Epstein's trial. And so Brunel is still criss-crossing the globe, trawling for 5'10" 13-year-olds from Eastern Europe and (the NA, h iter parts of) South America. And apparently taking the occasional ride with them on Epstein's private jet. Is there any better argument for the regulation of the modeling industry? http://nypost.com/2011/11/18/j effrey-epsteins-level-3-sex-offender-status-upheld-by-ny-appeal s- court/ 31 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 20111 5:00am Multimillionaire pery Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New York does. A state appeals court yesterday upheld the financier's status as a Level 3 sex offender — meaning he's considered "a threat to public safety" and a "high risk" to offend again. Epstein, 58, did 13 months in a Florida jail for soliciting a minor to perform a sex act on him during a "massage." Although he was never indicted or convicted for hiring any other underage girls, the state Appellate Division found there was "clear and convincing evidence" he had indeed done so, making the Level 3 designation appropriate. 32 http://pagesix.com/2007/10/06/model-shop-denies-epstein-tie/ MODEL SHOP DENIES EPSTEIN TIE By PageSix.com Staff- October 6, 2007 1 9:00am THE owners of MC2 models are denying industry speculation that massage maven Jeffrey Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, who was once accused of taking advantage of underage models. Epstein, who this week agreed to plead guilty to soliciting underage prostitutes at his Florida mansion in a deal that will send him to prison for about 18 months, reportedly gave "millions" to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. "E equals MC squared . . . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out," said a model industry insider. "He's a desperate old man that fantasizes and takes advantage of young girls." The trouble doesn't stop there. Karins Models founder Brunel, who's currently a partner in MC2, denied allegations in a 1997 "60 Minutes" segment that he took advantage of young models who were high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2, says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 15. He also dated Linda Evangelista when she was a teen. "He's also involved in the agency," said the source. "Gerald and Jean-Luc like the same things. They hang out because they have young girls in common, like two guys who enjoy the same wine." MC2 president Jeffrey Fuller confirmed Brunel was a partner in the company, but denied any working relationship with either Epstein or Marie. "We have no relationship business-wise with Gerald Marie. Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and 1 are the only two partners and owners of MC2 Model Management," Fuller said. Epstein's rep said he was not involved in the agency. "He has no business relationship with them," said Howard Rubenstein. 33 http://www.palmbeachdailynews.cominews/news/lawsuit-doeuments-link-jeffrey-epstein- to-modeling/nMGzHi Lawsuit documents link Jeffrey Epstein to modeling agency owner Jean Luc Brunel By Michele Daman Daily News Staff Writer New court filings in a civil case filed by billionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel, owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein's condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all over the world, promising them modeling contracts. "Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent," the documents say. Through the investigation of his lawsuits against Epstein, Edwards learned Brunel "runs the modeling agency MC2, a company for which Epstein provides financial support," the documents say. They also allege Epstein tried to thwart Edwards from taking depositions of Brunel, Epstein's companion Guislaine Maxwell, and other high-profile names such as President Bill Clinton. Details are listed in more than 62 pages filed by attorney Jack Scarola on behalf of Edwards in the lawsuit Epstein filed against Edwards. Edwards represents four of Epstein's minor victims, three of whom have settled their cases with Epstein under a confidential agreement. Epstein attorneys Christopher Knight and Joseph Ackerman declined to comment Friday on the court filings. Edwards deposed Brunel, but his attorney delayed it and then said he was back in France with no plans to return. But according to the court papers, Brunel was staying with Epstein in Palm Beach during that period. 34 The court filings describe Brunel as one of Epstein's closest pals. Regarding Maxwell, the documents refer to sworn testimony by Epstein's former house manager, Alfredo Rodriguez, explaining how Maxwell took photos of girls without the girls' knowledge, "kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims." According to the documents: Maxwell allegedly lied about her mother being ill and having to fly back to England one day before a scheduled deposition in Edwards' case against Epstein. Despite that assertion, Maxwell was captured in a photo for OK magazine, attending the wedding of Chelsea Clinton two days later. Epstein has settled more than two dozen lawsuits and claims against him by young women who say they were lured to his El Brillo Way mansion as teens to give him sexually charged massages and/or sex in exchange for money. The terms of all settlements are confidential. Rodriguez took a journal from Epstein's computer that listed the names of his underage victims from around the country and the world. Calling it the "Holy Grail," Rodriguez tried to sell the journal for $50,000 to victims' attorneys. He pleaded guilty to obstruction of justice and is serving 18 months in federal prison. Epstein, 57, served 13 months of an 18-month state sentence. He ended his one-year probation in July on state charges of soliciting prostitution and soliciting a minor for prostitution. According to flight logs from Epstein's private planes, Clinton flew several times on Epstein's planes, many times with Maxwell, Palm Beach resident Sarah Kellen and Adriana Mucinska — "all employees and/or co-conspirators of Epstein's," according to the court papers. The documents show that Clinton flew with Epstein, "then suddenly stopped — raising the suspicion that the friendship abruptly ended ... "Epstein's personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him ... and what appears to be Clinton's personal numbers," the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards' client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time, Doe was so frightened that she fled her home in the company of a retired police officer and was taken to a hiding place, according to the court papers. http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ 35 That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I've been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), I learn about, it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trqfficking Trafficked Athletes And now a new one I should have seen coming. Those very young, foreign models you see? Some of them were trekked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory trekkers; Go to politically or economically unstable areas; locate 5'l1" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. It's hard to think of an area of our society that doesn't admire seeing it's most vaunted members with a model on their arm. While this observation does not imply that those people were trafficked, imagine how simple that makes it to approach a child or it family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. I'm not shocked at traffickers using this method of promises to lure unsuspecting girls into slavery, I've seen it, read about it, studied it. I'm in shock that it flourishes in the most visible, 36 glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she 's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Samoll Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to 37 prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a 'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journaimagazine. In that story "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!" Ford recalls. "But I went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." 38 http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I've been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), I learn about , it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trekking Trqfficked Athletes And now a new one I should have seen coming. Those very young, foreign models you see? Some of them were trafficked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory trqffickers; Go to politically or economically unstable areas; locate 5 '1 I" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. It hard to think of an area of our society that doesn't admire seeing it's most vaunted members with a model on their arm. While this observation does not imply that those people were trqfficked, imagine how simple that makes it to approach a child or it's family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. 39 I'm not shocked at trqffickers using this method qfprornise.s to lure unsuspecting girls into slavery, I've seen it, read about it, studied it. I'm in shock that it .flourishes in the most visible, glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she 's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Samar Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges 40 have been filed by any of his accusers" — although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a 'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journaimagazine. In that story "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!" Ford recalls. "But I went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's 41 similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." 42 http://files.wallstreetfolly.com/wordpress/2007/10/jeffrey- epstein-doesnt-want-to-be-branded-as-a-sex-offender-for- life-and-no-hes-not-a-m odeling-agency-secret-sugar-daddy- or-so-its-owners-say/ Jeffrey Epstein doesn't want to be branded as a "sex offender" for life, and no, he's not a modeling agency secret sugar daddy (or so its owners say) Posted by WSF On October - 9 - 2007 \ inerrelftECI arty-Ham Jeffrey Epstein, Epstein, the billionaire money manager who's agreed to plead guilty to soliciting underaged hookers and go away for 18 months, doesn't want to be branded a "sex offender" for life. Page Six says his lawyers are thinking about asking prosecutors to drop that requirement from his plea agreement: In a letter drafted, but not sent, to U.S. Attorney Alexander Costa and obtained by Page Six, Epstein's lawyer, Gerald Lefcourt, writes, "Doing so will have a profound impact [on Epstein] both immediately and forever after. Not only will he be restricted to a wholly inappropriate penal facility, but he will be required for the rest of his life to account for his whereabouts." Meanwhile, over the weekend Page Six said that owners of MC2 modeling, run by Jean-Luc Brunel — who's also been accused of favoring underaged models in the past — claim that Epstein is not the secret deep pockets behind the firm, no matter what others say or speculate. 43 Epstein, __reportedly gave "millions" to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. "E equals MC squared. . . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out," said a model industry insider. "He's a desperate old man that fantasizes and takes advantage of young girls." "Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and I are the only two partners and owners of MC2 Model Management," [Jeffrey] Fuller said. [MC2 President] 44 http://www.washingtonpost.comincws/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-rules- that-discovery-can-move-forward-on-my-crime-victims-rights-act-case/ The Volokh Conspiracy Eleventh Circuit rules that discovery can move forward on my Crime Victims' Rights Act case By Paul Cassell April 21 On Friday,the Ilth Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case that my co-counsel, Brad Edwards, and I are pursuing. The narrow issue before the court was whether prosecutors and defense attorneys could assert some sort of "privilege" to prevent crime victims from reviewing the correspondence that lead to a plea bargain. More broadly, the ruling means that the victims will have a chance to return to the district court and seek to invalidate a plea agreement that (we alleged) was consummated in violation of their rights. I hope that the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach. Here are the important facts, taken from the 11th Circuit's opinion: The case arose in 2006, the FBI began investigating allegations that wealthy investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The U.S. Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the FBI issued victim notification letters to my two clients, minors Jane Doe No. 1 and Jane Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the prosecutors entered into a non-prosecution agreement with Epstein in which they agreed not to file any federal charges against Epstein in exchange for his guilty plea to minor Florida offenses (e.g., solicitation of prostitution). Not only did the prosecutors neglect to confer with the victims before they entered into the agreement with Epstein, they also concealed its existence for at least nine months. For example, the prosecutors sent post-agreement letters to the victims reporting that the "case is currently under investigation" and explaining that "[t]his can be a lengthy process and we request your continued patience while we conduct a thorough investigation." On June 27, 2008, the prosecutors informed my co-counsel, Brad Edwards, that Epstein planned to plead guilty to the Florida charges three days later. But the prosecutors failed to disclose that Epstein's pleas to those state charges arose from his federal non-prosecution agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. 45 On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 was a victim of federal sex crimes committed by Epstein and that the United States had wrongfully excluded her from plea negotiations. We also alleged that the federal prosecutors had violated her rights under the Crime Victims' Rights Act (CVRA) — specifically her rights to confer with the government, to be treated with fairness, to receive timely notice of relevant court proceedings, and to receive information about restitution. The United States responded by claiming that it used its "best efforts" to comply with the rights afforded to victims under the CVRA, but that the act did not apply to pre-indictment negotiations with potential federal defendants. After Jane Doe No. 2 joined the initial petition, the district court (Marra, J.) found that both women qualified as "crime victims" under the CVRA. The district court later rejected the government's argument that the act only applies after the filing of a federal criminal indictment. (I've written a law review article about the issue of how early crime victims' rights attach in the criminal process, which can be downloaded here.) Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims' rights. To make the case for such a remedy, we moved for discovery of the correspondence between the U.S. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the court should find that the materials were protected under the work product doctrine or, alternatively, should be protected under a new "common- law privilege for plea negotiations." The district court first ruled that rescission of the plea agreement was a possible remedy under the act. The court then ruled that we were entitled to review the correspondence, rejecting all of Epstein's arguments. On Friday, the 11th Circuit affirmed the district court's ruling that we could review the plea correspondence. At pp. 18-22 of its published opinion, the court concluded that there was no basis for restricting access to such correspondence when crime victims have a legitimate need to review it. The court rejected, for example, the work product argument because plea discussions are not confidential: Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., In re Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even jilt shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors' disclosure of their work product waived any claim of privilege. The court also declined to recognize a new privilege for plea bargaining, finding the relationship between prosecutors and defense attorneys did not need special protection: As a last-ditch effort, the intervenors contend that "[i]f more is needed in addition to the plain language of Rule 410 to preclude disclosure of the correspondence to plaintiffs, it can be found 46 in the conjunction of Rule 410, the work-product privilege, and the Sixth Amendment right to the effective assistance of counsel in the plea bargaining process," but this novel argument fails too. As explained above, Rule 410 does not create a privilege and the intervenors waived any work-product privilege. The intervenors concede too that the right to counsel under the Sixth Amendment had not yet attached when the correspondence was exchanged. Lumley v. City of Dade City, Fla., 327 F.3d 1186, 1195 (11th Cir. 2003) ("111he Sixth Amendment right to counsel ordinarily does not arise until there is a formal commitment by the government to prosecute," such as a "formal charge, preliminary hearing, indictment, information, or arraignment."). The "conjunctive" power of three false claims of privilege does not rescue the correspondence from disclosure. . . . The Supreme Court has identified several considerations relevant to whether a court should recognize an evidentiary privilege—the needs of the public, whether the privilege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996)—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiations. Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violated their rights under the Act. Moving forward, this case raises the important issue of what kinds of remedies are available for violations of the Crime Victims' Rights Act. Our complaint alleges that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal they had reached with him to avoid public criticism of the deal. I am hopeful that in future district court proceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure, and crime victims' rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Utah, he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C. Circuit and for Chief Justice Warren Burger of the Supreme Court, an Associate Deputy Attorney General with the U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S. District Court Judge for the District of Utah in 2002. In 2007, he resigned his judgeship to return full time to the College of Law, to teach, write, and litigate on issues relating to crime victims' rights and criminal justice reform. 47 --------Original message--------From: Jolanta MOD1LINOS Date: 15/10/2014 4:46 PM (GMT+02:00) To: Jean Luc Brunel Subject: Dear Jean Luc, Hope that you stay fine. As per our conversation about placement of her with you in NYC and Miami, she said she found some article in internet , which changed her position and she preferred to be placed with another agency.. I am so sorry, but people believes in media more than in us sometimes, what is sad! Warmest regards Jolania Sadauskiene owner MODILINOS model agency MODILINOS models Parodos 7-4, Kaunas Sv.Stepono 7, Vilnius tellfax:+37037323257 cell:+37069816103 iolantaAmodilinos.coni Thfo4modilinos.corn www.modilinos.corn EXHIBIT B From: "Vladimir Yudashkin © 1 MotherAgency" Date: 17/10/2014 10:46 AM (GMT+02:00) To: Jean Luc Brunel Subject: The situation with Liza Zazdravnih Dear JeanLuc, Unfortunately I need to announce that Liza Zazdravnih rejected signing the contract with MC2 in United Sates. Initially she intended to sign the contract, but later on she came across that article in internet about you involved in illegal activities with young models. This information somehow changed her intentions completely. she is ready to be a model and consider contracts with other agencies, but she has suspicions that you will force her to illegal activities and she made the decision to don't put her self in risk. Lets keep in touch. I will be happy to work with you next time if we have another right model for you. Im upset that it didn't work out with Liza Sincerely, Vladimir Vladimir Yudashkin Director EXHIBIT C -------- Original message--------From: Manuela - Mega Partners Date: 17/10/2014 9:36 PM (GMT+02:00) To: Jean Luc Brunel Subject: MC2 Dear Jean Luc, I'm very happy to hear you're coming to the agency with Vini so we can talk about us working with MC2 again. I don't need to remind you that the sex trafficking allegations have stopped us from working with • your agency for the past 5-6 years — but as Vinicius is my friend, I will try to find a girl that already knows and trusts him to place with you. Thank you very much for the lovely bag and we'll see each other on fashion week. Kisses, Manuela rn MEGA PARTNERS MANUELA W MARTINEZ International Relations Phone: +5611 3818.4800 Direct: +55 11 3818.4827 Cell.: +5511 98668.0090 megainodelbrasil.corn.br EXHIBIT D Original Message----- From: Lorraine <lorraine@mc2mm.com> Organization: MC2 MM Reply-To: <lorraine@mc2mm.com> Date: Friday, August 27, 2010 at 8:49 PM To: <jeff@mc2mm.com>, Jean Luc Brunel <jeanluc@mc2mm.com>, Pink <pink@mc2mm.com> Subject: FW: Press Inquiry from AFP (Agence France Presse) Videographer--Michelle Stockman -----Original Message----->From: Michelle STOCKMAN [mailto:Michelle.Stockman@afp.conn] >Sent: Friday, August 27, 2010 11:03 AM >To: lorraine@mc2mm.com >Subject: Press Inquiry from AFP (Agence France Presse) >Videographer--Michelle Stockman >My name is Michelle Stockman and I am a video journalist for Agence France >Presse, the French newswire. We produce 1.5 to 2 min. videos that are >distributed internationally to broadcast clients in Europe and Asia, and >Internet clients worldwide. In preparation for Fashion Week, my print >colleague and I are interested in doing a piece on trends in casting >models >of color. I was wondering if you could refer me to a model of color and a >casting director who can comment on her experience. >My deadline is next week, so I would like to set something up for Monday >or >Tuesday. I can come to you as I am a one-person camera crew. When you >have >a moment, please let me know. I'd be happy to discuss with you over the >phone ahead of time. >Best regards, >Michelle Stockman >Michelle Stockman >747 Third Avenue, 35th Floor >New York, NY 10017 EXHIBIT E >917-533-3261 >www.youtube.com/AFP >Agence France-Presse is the world's oldest newswire with journalists in >165 >countries. We publish worldwide in English, French, Spanish, German, >Portuguese and Arabic. AFP delivers the news to thousands of media outlets >worldwide from newspapers to magazines, radio and TV stations and online >services. It reaches an audience of more than one billion people daily. >This e-mail, and any file transmitted with it, is confidential and >intended >solely for the use of the individual or entity to whom it is addressed. If >you have received this email in error, please contact the sender and >delete >the email from your system. If you are not the named addressee you should >not disseminate, distribute or copy this email. >For more information on Agence France-Presse, please visit our web site at >http://www.afp.com EXHIBIT E Sent from Samsung Mob.le ------ Original message From: Michael Sanka Date: 12/12/2014 12:48 (GMT-05:00) To: Jean Luc Brunel Subject: Scouting Jean Luc, How are you? After so many years scouting for you and having a great network of agencies all around the world who enjoy to work with us, i wanted to let you know that we are on the way to lose everything we build and we are gonna have big problem now. Agencies, still want to work with us but parents don't want their daughters to come to us, because when they google your name and the agency name the only things they see is "Sex Trafficking"!!! It's impossible to sign a new girl and if nothing it's done i can tell you that in 3 months we we will not get any new girls and i don't see how the agency will work without new faces. All the agencies who know you don't have any problems with you since they all told me "We know Jean Luc for more than 20 years and all those years we had so many girls place with him who had better experience than in any other agencies who were representing them as well and we never had any problems whatsoever, all our girls had great carriers as a model when he represented them". I understand those agencies because it's hard for them to talk to parents and explain that it's not the truth when it's all over the internet. You need to have it stop and have the people write an official letter to say that it's not the truth... I will keep you posted of course but it's really bad for us and the scouting. Best regards - Michael Sanka 3104021028 EXHIBIT F FOX r sH infq GLCv Ann: Scouting division MC2 We took notes of your comments and the girls that you like on our website. We know Jean Luc Brunel and we always work with him since more than 10 years all those years and never had any problems. All the girls he represented from us never had any problems, they were working have great book work with good clients in editorial and campaigns and were well represented models. Now for all the new faces we have, we needed to talk to their parents to discuss about mc2 and you interest to represent their daughters and of course they google it and saw all the had articles about sex trafficking they were scared and I was myself speechless since we know that it's not true but it was hard for us to explain to the parents. So of course for the moment till all is clarified we can't place any new faces with you because the parents will refuse and it makes us look had to propose the girls to your agency. We are sorry but you really need to clarify everything, till then we will have to cease any collaboration and we will have to refuse to let you represent any of our models. Sure you understand. Sandra Petkanic Fox Fashion Agency Beograd 11000. Svetogorska 35 v. Stan 12 www.foxmodetcom e-mail: foxaffice@sezampro.si EXHIBIT G Tel +381 11 3346414, tel +381 11 3226202 1 Q As part of your employment with MC Square 2 did you live in New York, for a time? 3 A I'm sorry, but I take the Fifth. 4 Q Have you ever heard any model of MC Square 5 who at the time of being a minor, that means under 6 the age of eighteen, made an accusation that 7 8 A Never. And that is something that I will 9 not answer. And I said never because even when 10 peoples come and ask me I will always say the truth 11 regarding that. 12 I know Mr. Brunel for the longest -- 13 maybe eight years. And I always said what I know. 14 I never saw and I never knew that he did anything. 15 So I know that. And that's the truth. 16 Never. I never heard anybody accusing Mr. Brunel 17 18 Q That means -- that means at any time no 19 model, no minor model came to you and said, you 20 know, "Maritza, look what just happened to me", that, 21 22 23 24 "I don't have a place to live". Or, "Look, I didn't 25 get my ticket", or whatever. EXHIBIT H-1 Jean-Luc Burnel acted inappropriate with her? or complaining about Mr. Brunel. Nothing. "something bad happened to me". A Maybe a model came and told me, "Maritza, look what happen to me. I don't have any money," or 43 1 a-- 2 MR. OBRONT: Well, I would object, because 3 of circumstances. 4 BY MR. DAVID: 5 Q But you said before that you never heard 6 anything that would indicate that Jean-Luc Burnel 7 behaved inappropriately with -- with any models, q especially any minor models that MC Square may have 9 had. 0 Is that correct? 1 A Yeah, I said what is the truth. Nobody 2 complain to me. Nobody -- your question was very 3 clear, has any girl came to you and complain about 4 sexually, you know, involved with Mr. Brunel. 5 Q Right. 6 A And my answer was no. Nobody came to tell 7 me. I never saw. I never knew. His personal life 8 was not my problem. Do you have any actual knowledge, that is 0 to say were you present or did you see with your own 1 eyes, any minor models go with Jean-Luc Burnel to 2 Jeffrey Epstein's home, or any party of his? 3 MR. OBRONT: Objection. 4 THE WITNESS: I'm sorry, but I take the 5 Fifth. EXHIBIT H-2 COMPOSITE EXHIBIT I INI Iti. 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V.4•144w, tallItint; MOrT 410. ... .00 Ott... Omw.t AMOR Otito/i... - dr! 11,1trim Tara Al.+ lataL/00). SUPPORTING DOCUMEPOS EXHIBIT 1 Several press and media articles documenting the rise of South Beach as one of the United Slates' main fashion capitols. EXHIBIT 2 Press articles regarding the models and actresses who were both discovered by and careers were launched by the beneficiary. Jean Luc Brunei. EXHIBIT 3 Several articles regarding the prestigious reputation of Kann tviadets as formerty one of the world's leading agencies. EXHIBIT 4 A list of all of tiAC2's clients, including several high-profile campaigns featuring some of MC2's fashion models. as well as several press clippings regarding this prestigious and reputable modeling agency. EXHIBIT 5 The beneficiary's. Jean Luc Brunel. impressive curriculum vitae, verifying his tremendous accomplishments in both the fashion and modeling industries. EXHIBIT 6 Several articles regarding the 2004 Models New Generation Contest (including translations) as we as the beneficiary's leading role within this prestigious modeling event. EXHIBIT 7 Several press orlicles regarding the prestigious 2006 Models New Generation Competition (including franslatiansl, as well as the beneficiary's Jean Luc Brunel, leading role within Illt event. EXHIBIT 8 Letter of Claudia tviiiaolo, President of Modetwork. a renowned modeling agency. EXHIBIT 9 Letter of Alia Amonlova. Director of Faro International Management. EXHIBIT 10 Several press articles reflecting the prestige and high circuiarian rates of the mentioned mngazines and periodicals which have featured and covered the modeling events which the beneficiary. Jean Luc Brunel, hos Organized throughout the year. EXHIBIT 11 Information regarding the extremely successful and prestigious modeling and fashion association, International Model Taieni Association (IMTA), M C NIODELSMIAtvil July 25. 2014 Department of Homeland Security United Stales Citizenship and Immigration Services Vermont Service Center 30 Houghton Street Saint Albans. VT 05478 RE: 1-129, Petition for a Nonimmigrant Worker 0-1 Extraordinary Ability as an Art Director and Talent Coordinator Petitioner: MC2 Models Miami, U.0 Beneficiary: Jean-Luc Didier Henri-Rene BRUNEL Dear Sir I Madam: The present fetter and its enclosures are submitted in support of the attached 0-1 petition of MC2 Models Miami. LIC, on behalf of Mr. Jean Luc Brunel. The petition is based upon Mr. Brunel's standing as an "Alien of Extraordinary Ability in Art Direction and Talent Coordination." Kindly note that Mr. Brunel currently holds 0-1 status with our organization. The South Florida area and Miami Beach in particular have become a mecca for the fashion and modeling industries. As a result many of the largest international modeling agencies such as Ford. Elite, and MC2 have opened offices in South Beach and the area has become one of the most important in the modeing industry In foci, Miami Beach has become second only to New York City in terms of employment opportunities for fashion models in the United States. Attached as EXHIBIT 1, please find several press and media articles documenting the rise of South Beach as one of the United States' main fashion capitals. In 1996. our company, MC2 (formerly Karin Models}, established an office in lhe heart of the historic Art Deco District of Miami Beach. "South Beach' has truly become one of the world's modeling capitals and we are pleased to be a Pcirf of il Our agency has developed a highly distinguished reputation in the modeling industry. We specialize in representing numerous moaels of infernailanal acclaim. Having discovered faces such as Christy Tixlington, and molded the careers of celebrities such as Sharon Stone, Estella Warren. Milo awe' mods maw- • 1674 Won mad • su)1e 640 • mialTh beacti I133134 Nab 672 6300 • fa: 305 531 8330 • adminostration 305 672 7672 • fax 345 672 6332 rric2trim Jovovich. Jerry Hall and Rebecca Romiin who is currently starring in the award- winning ABC television series. Ugty Betty; MC2 models are among the most sought after in the industry, as evidenced by the caliber of their commercial and editorial bookings. Many of our fashion models have graced the pages of leading fashion magazines of the United States, Europe„ Latin AMeriCO. Africa. and Australia such as Vogue. Teen Vogue. ale. W, Glamour. V. Mane Claire. Surface and Cosmopolitan as well as many more throughout the world. In addition to our Miami Beach office. MC2 Models has offices in New York City and Tel Aviv. Israel. As Artistic Director and Talent Coordinator tot MC2 Models Miami. (IC. Mr. Brunet will be responsible for overseeing the artistic aspects of the agency. By overseeing the art department in the agency. Mr. Brunel will direct the visuar marketing of the models to clients. focusing on the images placed on both the model's composite cards and their portfolios. Both of these marketing tools are crucial in marketing fashion models to their appropriate catalog, editorial, or media clients. As Artistic Director and Talent Coordinator, Mr. Brunei will also ,:oorciinate the pairing of fashion models with a particular photographer. Clients for the agency include a myriad of fashion pubfications, retail stores, consumer oracluct companies, and fashion houses lo name but a few. Recruitment of talented artistic photographers who have an exceilent understanding ot the 'ins and outs" of the modeling and fashion industry is cnbcal to the successful running of a top-modeling agency such as MC2 Models. Mr. Brunel will also continue with his amazing track record of discovering the world's greatest talents and beauties in order to sign them with MC2 Moclet.. Mr. Brunel will continue to travel around the works looking for new talents, and to agencies around the world in order to establish relationships with those agencies and allow MC2 Models Miami. Li.0 io represent them in the United Slates. Mr. Bruners impressive Qualifications as an Art Director and Talent Coordinator, establish eligibility as to the regulatory standards for such classification as a top professional in his field. Mr. Brunel meets the 0-1 criteria as an individual of extraordinary ability in the Arts and Entertainment field as well as a business entrepreneur. MC2 Models Miami. 1,1C is presently seeking a cophisticated art director and latent coordinator. After reviewing his experience and accolades, we ore confident that the beneficiary, Mr. Jean Luc Brunel, will perform said function with outstanding kiii and professionalism. J. MR, BRUNEL'S QUALIFICATIONS AS TbE RENEFICIARY In addition tc, Jean Luc Brunei's extensive business Qualifications, his -weer as art individual with artistic vision and creative talents Qualifies him as an 0-1 alien in the Arts and Entertainment Field His all- encompassinin experience as art Art D'ector, Talent Coordinator. international entrepreneuo and business leader in the modeling, fashion, entertainment, public relations, restaurant. and tourism industries has made Mr. Brunel internationally renowned in Those fields. Among his various accomplishments throughout his career are the successful modeling agencies he has founded both in Europe and in the United States. For example. in 1978. Mr. Brunel founded and grew Karin Models Paris from the ground up to become a lead-market agency with a world-wide presence. Capturing a strong market share in Paris, Mr. Brunel successfully created Karin Models as a platform for marquee clients to obtain sophisticated public relations services and important modeling contract opportunities. Mr. BruneI's success was so great with Karin Paris that in the next ten years. he founded Next Model Management in Los Angeles. California in 1980. Next Model Management in Miami, Florida in 1982, Mode/ Management Group also in Miami. Florida in 1966. and Rebecca Commercial Casting in New York City. in 1988. The loiter one was opened as a talent and casting agency for performers. offering services such as voice-overs, television, and cinema advertising work. again. successfully carving out a niche by which to make his mark and achieve bold commercial performance results. Although Mr. Brunel later sold his rights to Next Management to Faith Kates in 1989, who partnered with Joel Wilkenfelcl a couple of years later; NEXT represents some of the most prestigious women and men in the fashion world today. Star talent includes renowned fashion models Molly Sims, Daniela Pesiova. Audrey Quock. Yamila Diaz. and Malgosia Bela. NEXT continues to maintain an influential international force in the fashion and modehng industry through its fully operational offices in New York. Los Angeles, Miami. Sao Paolo, Montreal, Landon. and Paris, as well as its affiliates in Milan and Australia. Because of strong revenue growih and successful business performance. as a result of his ariislic vision as an artistic director and talent coordinator. Mr. Brunel founded the very successful Karin Models of America in New York City and Karin Models USA in Miami Beach. Mr. Bruners commercial ventures in opening Karin agencies in Paris. New York. and Miami have been extremely successful, generating combined annual revenues of twenty five (25) milion dollars. Eventually, Mr. Brunel hcensed the Karin name to agencies In Israel, Denmark. Germany. and Spain. Mr. Bruners extraordinary talents are not only limited to launching successful modeling businesses. but also in discovering and launching the careers of some of the world's most successful models. Mr. Brunel has launched the extremely successful careers of supermodels such as Christy Turtingion. Rachel Hunter, Sharon Stone. Monica Bellucci, Estella Warren, and Christina Semonnovskaya. These women all proceeded to become some of the most photographed international cover models in the world, appearing on Thousands of magazine covers woirictwide and spanning many years. As a result of his reputation as a highly visible, strategic networker who cultivates and conducts business in a global environment and bookers lucrative cleats, mory lop players in the fashion and entertainment field requested that Mr. Brunel function as their exclusive agent and representative. Some of these top former and present professional supermociels in the fashion field include. Naomi Campbell. Christy Turiington. Rebecca Romijn, Mia Jovanovich, Inez Sastre, Melanie Thierry. and Jerry Hall. Attached as EXHIBIT 2, please find press articles regarding the models and actresses who were both discovered by and careers were launched by the beneficiary. Jean Luc Brunel. Additionally, attached as EXHIBIT 3, please find several articles regarding the prestigious reputation of Karin Models as formerly one of the world's leading agencies. Most recently in October 2005. and after his reign with Karin Models, Mr. Brunel launched the prestigious MC2 Model Management worldwide with offices in New York. Miami and Tel Aviv. Mr. Brunel storied the high-profile MC2 Model Management in order to represent high fashion models in a boutique agency setting. MC2 Model Management is already being lauded by fashion insiders as "one of ihe hottest agencies in North America" as well as "prominently positioned to be one of the major players of the Zeros because of its insider relationships with the most influential photographers around." We invite you to visit www.m_c2rnm.cpm in order to view the high-caliber of models. MC2 represents Some of Hs most recent successful bookings include Liu Dan'', exclusive contract as the face of the Fall 2007 Guess Campaign and Sammy Jo's cover story for Cosmopolitan Magazine. Attached as EXHIBIT 4, please find a list of all of MC2's clients, including several high-profile campaigns featuring some of MC2's fashion modes, as well as several press clippings regarding this prestigious and reputable modeling agency. Jean Luc Bruners entrepreneurial spirit is not only contained to the field of arts, beauty. and fashion. In 1970. as a result of his business insight, Mr. Brunel founded and grew Jean Luc Relations Public:we, which specialized in press and promotions for tour operators and restaurants in France. During his work through Jean Luc Relation) Public:we. Mr. Brunel represented various key clients and collaborated on numerous prestigious events. Some of the prestigious events include.. Air Tour and Daro Voyages. Jean Luc Relations Fubliaue also promoted and marketed La Tour D'Argent, a three-star restaurant owned by Claude Terrait and. "The Go-Between", a motion picture by George Losey. Other projects token on by Mr. Brunei through his public relations company was his work as product agent for Jean Claude Kitty. 1968 Winter Olympic Gold Medalist skier, to promote Vail. Colorado in France for tourism potential arid also directed all of the promotion for Finland's Ministry of Tourism. In 1975, Mn Brunel further invested in the Food and Hospitality market by creating and developing "El Mono Desnudo"- a legendary, high-end bar on the Iberian Peninsula. This bar was known throughout the peninsula as extremely exclusive and attracted a celebrity clientele that included actress, Ursula Andress, and lhe Duchess D'Alba. Attached as EXHIBIT S. please find the beneficiary's. Jean Luc Brunel. impfessive curriculum vitae. verifying his tremendous accomplishments in both the fashion arid modeling industries. II. ELIGIBILITY FOR CLASSIFICATION AS AN ALIEN OF EXTRAORDINARY ABILITY THE ARTS Under the Miscellaneous and Technical immigration and Nationality Amendments of 1991, petitions for classification as an Alien of Extraordinary Ability in the Arts must be supported by evidence of "distinction". According to 8 CFR §214.2(o) (Mil), "distinction" means a high level of achievement in the field of arts as evidenced by a degree of skill and recognition substantially above That ordinarily encountered to the extent that a person described as prominent Is renowned, leading, or well-known In the fields of arts, This evidence may consist of proof that the alien must be recognized as being prominent in his field ot endeavor as demonstrated by the following according to 8 CFR §214.2(0)(3) (iv): A. Evidence that the 05en has been nominated for or has been the recipient of significant national or inlernational awards or prizes in the particular field such as an Academy Award, an Emmy, a Grammy. Of a Director's Guild Award, or B. At least three of the following forms of documentation: (1) Evidence that the alien has performed, and will perform, services as a lead or starring participant in productions or events, which have a distinguished reputation as evidenced by critical reviews, advertisements, publicity releases, publications contracts, or endorsements; (2) Evidence that the alien has achieved national or International recognition for achievements evidenced by critical reviews or other published materials by or about the Individual in major newspapers. trade journals, magazines, or other publications: (3) Evidence that the alien has performed, and will perform, In a lead, starring, or critical role for organizations and establishments that have a distinguished reputation evidenced by articles in newspapers, trade ,journals, publications, or testimonials: (4) Evidence that the alien has a record of major commercial or critically acclaimed successes as evidenced by such Indicators as title, rating. standing In the field, box office receipts, motion picture or television ratings, and other occupational achievements reported in trade Journals, major newspapers, or other publication'', (5) Evidence that the alien has received significant recogntHon for achievements from organizations, critics, government agencies, or other recognized experts In the field in which the alters Is engaged. Such testimonials must be In a form, which clearly Indicates the author's authority, expertise, and knowledge of the alien's achievements; or (6) Evidence that the alien has either commanded a high salary or will command a high salary or other substantial remuneration for services in relation to others In the field, as evidenced by contracts or other reliable evidence; or C. If the criteria In paragraph (o)(3)(1v) of this section do not readily apply to the beneficiary's occupation, the petitioner may submit comparable evidence In order to establish the beneficiary's eligibility. EVIDENCE THAT THE BENEFICIARY MEETS AT LEAST THREE Of THE PRONGS OF THE CRITERIA UNDER $VBSECT1ON 0 The afg_mitng that the beneficiary satisfies is gl CPR 4214,2foX3IfirOf8)(1), which requires evidence that the alien has performed, and will perform, services as a lead or starring participant In productions or events which have a distinguished reputation as evidenced by critical reviews, advertisements, publicity releases, publication contracts, or endorsements. As a result of Mr. Brunei's combined expertise in fashion and tourism, he decided to create Latin Model Pageants, now known as Models New Generation- to cross promote these key industries with international business and investment opportunities. Mr. Brunel has promoted and judged various modeling contests throughout South America including modeling contests staged in countries such as Peru. Ecuador, Brazil, Argentina. and Chile. Conceived in 1987, the Latin Model of the World event was a high-end modeling and entertainment product that appealed to upscale international audiences. reaching nearly 400- million television viewers worldwide. Throughout his history as a major infernalionai event promoter and artistic and talent co-ordinator, Mr. Brunel has orchestrated multi-faceted public relations. advertising and media campaigns that incorporated television, magazines, programs. newsletters, and promotions. becoming notably lucrative for various major brands as a promotional tool. Mr. Bruners acute knowledge of marketing and promoting skills has turned his various international events into highly successful artistic and business ventures tar various major brands Latin Model Pageants attracted major brands as sponsors, such as American AfrOnes, Ray-Ban, Coca-Cola, Proctor & Gamble. and Revlon. Mr. Brunei's has continued his ventures as both a promoter and panel judge when he founded and created the international modeling contest, Models New Generation !hat took place in Guayaquil, Ecuador in 2004. Mr. Brunei sat on a panel with three other professionals in the fashion industry and judged over forty-nine young women from over North and South America. Asia, and Europe. After len days of harsh competition, Jean Luc Brunel crowned the winner, Alyne Weber. a fifteen year old from Brazil, whom as a result of coming in lust place was awarded over three hundred thousand dollars worth of modeling contracts. The city of Guayaquil. Ecuador was also thrown into the international spotlight as the host city for the modeling contest. The Models New Generation was broadcasted on numerous television network channels including. Fashion TV, which transmits to over 202 countries throughout the globe, the entire Association of Television Channels in Ecuador, National Television of China, and Recle Globo. Brazil's largest and most popular television network. Attached as EXHIBIT 6, please find several articles regarding the 2004 Models New Generation Contest as well as the beneficiary's leading role within this prestigious modeling event. As a result of the tremendous success of the first Models New Generation that look place in Guayaquil. Ecuador in 2004, Mr. Brunel organized the second Model New Generation Contest which was held in 2006 in the Ecuadorian capitol of Quito. In order to select only the very best new models, several Preliminary. qualifying shows were held in different countries of Latin America including Bolivia. Panama and Peru. The final conies: was held in Quito, Ecuador at the historical Plaza San Francisco. Mr Brunel sot on a panel with three other professionals in the fashion industry and judged over forty-eight young women iron' twenty-eight different countries from North and South America. Asia, and Europe. After ten days of harsh competition, Jean Luc Brunel crowned the winner. Gird° Lapina, an eighteen year-old. from Latvia, whom as a result of coming in first place was awarded over three hundreo thousand dollars worth of modeling contracts. The city ot Quito. Ecuador was also thrown into the international spotlight as the host city for the modeling contest. Again. just like the immense media exposure given to the first Models New Generation competition of 2004, the 2006 Models New Generation competition was broadcast on numerous television network channels including, Fashion TV. which transmits to over 202 different countries throughout the globe, the entire Association of Television Channeh, in Ecuador, National Television of China. and Rede Globo. Brazil's largest and most popular tetevision network. Attached as EXHIBIT 7, please find several press articles regarding the prestigious 2006 Models New Generation Competition, as wel as the beneficiary's Jean Luc Brunel. leading role within the event. The 2006 Models New Generation program was broadcast in over 202 countries throughout the world. Mr. Brunel has performed and will most definitely continue to perform services as a leading participant in modeling events, which have a distinguished reputation and wilt bring more public international light to MC2 Models. For the above-rnentinneOr.m.r1,ns,, 131uriel Satisfies INA §214.2(a)(3)tivi (B1( I ). The second prong that the beneficiary satisfies is 8 SJI fa14,2(03)fiv)fBn. which requires evidence that the alien has achieved national or International recognition for achievements evidenced by critical reviews or other pubtisned materials by or about the Indlvidvol In major newspapers, trade journals, magazines, or other pubecations. Mr. Brunel holds an international reputation as ci visible. strategic rietworket who is able to cultivate expert relationship management skills in cider to conduct business in a global environment and broker lucrative deals. Mr. Brunel has a long history in marketing and advertising maim fashion campaigns. throughout his twenty-five year career in the fashion business, Mr. Brunel has developed vvotidwide exclusive modeing and cosmetic campaigns. Some of these major cosmetic campaigi% include: Bio Therm with supermadel Etle McPhersor., PeAS with Rebecca Rornijn, Christian Dior with Christina Semonnovskaya. Margret Astor with Monica Bellucci. Chanel with Patricia Von Rickenheim. Angel Perfume with Thierry Mugler. and Cacharei Perfume with Aida BaHestia. Mr. Brunet has also developed major fashion campaigns and has developed campaigns and exclusive contracts with some of the waticrs top fashion designers such as Yves Saint Laurent. Chanel. Christian Dior. Gucci, Nada and Marc Jacobs Please see the enclosed letter of Claudia fvtidolo, President of Moctetwork, a renowned modeling agency. EXHIBIT B. As a talent coordinator, Mr Brunei's success can arid should also be measured with me 3ucce55fu1 careers the models. whose careers he launched. have achieved As slated above. Mr Brunel has discovered and represented various ruper models throughout his career. Christy Turlington. who was discovered by Mr. Brunel, has personified unaffected beauty- representing Calvin Klein's fragrances since 1987 Turtington. as well as another model represented by Mr Br unel. Naomi Campbell, becarnt- one of the few superrnocie6, who managed to make on easy transition from the haute glamor of th 19BO's to the relaxed simplicity of the following decade. Throughout hei extensive career, arid as a result of Mr. Brunet's "Fashioii- Savvy Eye", Christy Turiington tio graced the cover of hundreds of fashion magazines. surf*, as Casmopotital ,, W. vogue, Shape, Fitness, Elle. Bazaar. mcirie Claire. Harpers. Esquire, and even Time Magazine. Please see the enclosed letter of Alla Amantova, Director of Figaro International Management. EXHIBIT 9. In (addition. the modeling events that Mt. Brunel has been organizing throughout the years receive not only national, but also international attention and appear in multiple publications around the world. One of the most recent events he organized. the Models New Generation contest, which took place in Ecuador was publicized and transmitted by various television networks and appeared on multiple newspapers and magazines, among them Globo Television Networks in Brazil. Fashion TV which is broadcast into 202 countries throughout the world, El Univers°, Cows, La Razon, El Diario. El Telegrafo. Notinorfe, Extra. Hoy. El Gran Guayaquil El Comercio. Semana. and 8 Lideres. to name a few. These major publications have a large subscription rote which numbers in the many millions of readers. Attached as EXHIBIT 10, please find several press articles reflecting the prestige and high circulation rates of the above-mentioned magazines and periodicals which have featured and covered the modefing events in which the beneficiary. Jean Luc Brunel. has organized throughout the years. Hence the beneficiary satisfies NA §214.2{031(iv)(13)(2) for having achieved not only national but also international recognition for achievements in the modeling industry, by having his work published in major newspapers and magazines throughout the world. The third prong that the beneficiary satisfies is 8 CFR 4214.26,1(310001f4), which requires evidence that the alien has a record of major commercial or critically acclaimed successes as evidenced by such Indicators as title, rating, standing in the field, box office receipts, motion picture or television ratings, and other occupational achievements reported in trade journals, major newspapers, or other publications. One of the main reasons that Mr. Brunel has been able to not only survive, but also be extremely successful in the ever-changing world of fashion is his ability to identify and recruit star-quality talent, As a result of his ability to scout major talents, Mr. Brunel was invited to become a member in one of the fashion industry's most elite and important associations, the International Model Talent Association (hereinafter IMTA). The MIA is an international association of training centers for models and talent. IMTA gives aspiring models. actors, singers. and dancers spectacular opportunities to showcase their potential talents in front of too fashion and talent agents from the major markets of the international fashion industry. IMTA also provides its association members valuable marketing tips and networking events with agents and scouts from around the world. Several of todays up and corning actors arid models have been discovered at IMTA; some of these discoveries include world-renowned actors such as. Elijah Woods, Ashton Kutcher, Katie Holmes, Eva Longoria. Jessica Biel, and Sean William Scott, Attached as EXHIBIT 11, please find information regarding the extremely successful and prestigious modeling and fashion association, IMTA. Additionally, please find several pages from IMTA's official website documenting their discovery of the above-mentioned Mist actors and actresses, whose membership in IMTA proved to be the launching pad for very successful and highly profitable careers in the film industry. Furthermore, as previously mentioned. Mr. Brunei has launched the successful careers of many internationally renowned models, who have been featured and still are in many international and nalional fashion magazines. In addition, his commercial ventures. especially MC2 Models. formerly Karin Models, have been extremely successful generating combined annual revenues of twenty live 125) million dollars. Currently MC2 is one of the most successful and well-known modeling agencies in the world. Mr. Brunel is one of few people in the modeling business that have achieved a similar standing and have been able to maintain it for over twenty-five years. For the above-mentioned reasons, Mr. Brunel satisfies INA §2144.2(o)(3)fiv)(8)(4). EVIDENCE THAT THE BENEFICIARY MEETS 8 CFR B2141(01f3IfIv)fC) The petitioner has submitted a plethora of evidence regarding Mr. Bruners experience in the fashion modeling industry. Mr. Bruners has established MC2 Models, formerly Karin Models, which is presently one of the major international modeling agencies. with combined annual revenues of twenty five miDion dollars. Only someone with Mr. Brunei's expertise and strong strive for success can achieve such international acclamation in the industry and been able to maintain his status for over twenty-five years. Mr. Brunel is the one responsible for the launch of numerous supermodels' careers, which hove been maintained in the spotlight for several years. He has worked with renowned fashion designers and photographers, who have trusted his work and intuition. In addition, Mr. Brunel has orchestrated many international and national successful fashion events that have received international acclamation. For the above-mentioned reasons, Mr. Brunel in addition to meeting at least three of the criteria of 8 CFR §214.2(0)(3){1v)(8). he also qualifies under 8 CFR §214.2(0)13)(1v)(C) Ill. CONCLUSION It is clear from the evidence that Mr. Brunel is eligible for classification as Lin Alien of Extraordinary Ability in An Direction and Talent Coordination based upon his meeting the eligibility requirements under the Immigration and Naturalization Act 101(a)(15)(0)(1) and 8 CFR 2)4.2(o). Mr. Brunei's successful career proves that he is a prominent. leading. and well-known person in the field of arts. Mr. Brunel's extraordinary ability in the field of arts, in which he witl continue to work in the United States, has been demonstrated by sustained national and international acclaim. Based on the foregoing, we respectfully request your kind consideration and favorable determination of this petition, in order to accord Mr. Brunel the classification as an Allen of Extraordinary AbIlity in Art Direction and Talent Coordination. Again, kindly hate that the beneifciary, Mr. Jean Luc Srunei, has held 0-i status In the past Wherefore, for the above-stated reasons, we respectfully request your favorable adjudication of the 0-1 nonimmigrant visa petition submitted by MC2 Models Miami. LLC on behalf of Mr. Brunel. If you should have any questions or requie any additional documentation, please do not hesitate to contact our office. Thank you very much for your kind attention regarding this matter. Truly Yours. Mien. September Os, sou" USW Vermont Semler Outer 75 Lower Weide° Street Bt. Album:4Yr osen-000i BE 0-i Non-immignint V Maine on iwitalf al Jean We Dither Henri•Itene Brunel I write this letter in t.trong sup;x,rt of Mr. Jean LUC Bruner:, applicAton for A non-inunigrard Visa to this oountry. I am currently Aninalnistratorr Unice, In Studio Pp. I ha,,x: been asked to review the professional credentials of Ma Brunei, and it i5 my profest,ional opinion that Ms. Brunel is an Art Director and Tak-nt Coordinator of ettinerdibary ability who ranks among the mnIIparentage of foreign people at 'red. top oaks field. I have seen first-hand Mr. Jean Wes special expertise in the field. intbding entity. production. coordination. and art direction for shoota. Ur. Brunel is considered by those in our Wintry to bean extraordinary creative director talent, particularly for the fashion and related indostrie:i. In zny personal dealings with Mr. Jean Luc Brunel, I found him to he thoroughly professional and capable of being utilised in connection with a wide range of creative subject matter on any ainivinient. He has liw intuitive ability to provide just what's needed in connection with any particular cmtive process and possesses excellent artkic ossmuternent and operational skills that come from his years of experience. Many people do not understand that behind every IncOessfut ad‘ertis.ing campaign and fashion shoot there are creative wen and wants who are making sure that the business operates efficiently by coordinating different tasks between models, photographers, and managing avative team. I can honestly say that Mr. Brunei continually prom, himself as an extraordinary talent its his field, offer an unmitigated endorsement for Mr. Jean the Brtinet regarding his. dart application asi a person of extraordinary ability. Th'pre is no doubt in my mind that his popularity and ability in the field will only =time to prç,per in pears to come , ! f.m! Ivry. t . :441, 744 ra sasmeast tt•Ps 41116/14 %MOM fbrevtai Color /Siemer Weider. Ittreet Si Album '17 0.5474-4101.) t SKI 0.1 filossemooswoot Viso Vrtitoso ' of Agar - ilirisreeo Disr Ow or Maims I *Wit doe trtlirr 41$ straw aupport of Idr Jean L...c Briariefe tappitcaiwn rpm a r-zo 11111110Witit visa ft MA OPUtlir; oft cefiretly uurkiraz as an Awrot is TwO Malillipaben1 We &gees Based mph my eisiriang is thir fieki of ti:o litsituovat tedueise *ea frequently Cad to tirdieein tiw ontotrustiolo of r>thfir i...nnftwgctiati m $hp fedd I have born *Ord 10 MOW fiiit protest:tom! ciredeestiahi of Mr. sky:,,r, Luc ersoet It be y prokoluGnitS optnirn, lootd upon toy petwof and prolenotootolI linooloollse of *. amulet* udentri, that Vir. Wood re en oft director of ceirrievainary Who* who ranks among tht. ormeil rarceltimp of keeign ptrAteitatugeatwore top alma that I Wel* atom Joao Lu nuid and aser4 a pkaisinive Iowa with IWO a teibraiard perms_ ithadmi biy the Pugh !walk IllaterSIM et :ht comperises with *twit he reiguirf% • thearb S am wail the cvnl; oar who *wettable his Woo, Hi* rttotirlst!furty appc4ied an my tit die' weld* most pup4itpublicetione. eriacheig Ikterony uaierre er adounes • perttriiiikit foamy, kir Ms work in to V•tirn, oderrheirg arid rd'109a1 world his medsikothoes Sc soktai stools. ouch oh itkiteld IOWA. 011014. Moe' New lietvrid MN • ignition as gm itt the loadma hist Whom an doectors sores* IV-day. Jew im- am* Is the vonstmemnotit prolomoonal vitykrt at row to tho 571 01 bathos ond hot wart as learitharni frieirittes twat elite oiesistraire A tree who lir in cutturittei TO MO elitellellats of Ow dant on rnecy eccoserti fkitiexilh Mt *wet i-m-yrrtiowle thy heihrei thoormotthos for has wit. lie to weft worth the met Mr.Jtoet Lair Snow a UNistillattsultoty at COM- Ina enerv.. moortsoriatiol isalaaverawral strict eckeoeigidirrurt-ri Should you hew ow ILrlitv,ril Mr buss!. mUwdasw abslfl. &nee foci belt to comae too Moak sou lor yr otterttiosi aria rortsederstoss. OREOKADEILIITUDIOS oroyarmatmer Ltd tow 1111.0 peoli tritiii gala tfilt0111121001111111111011.tain bø b1 som 418011 %mid bola Casa 2$ tom Weldesiltiett Ahem Vf 064Po -cool BD O11420-kaasigesat Visa Fabian on Mullet Joan Lac Brand Door& at Itadsav letttr im writtext to support the vim a-WIT-maim ofJcan Lac &mei .0 that he may be accorded 0-i inctraortEnary thfly101111 tai= Iaoatitinuc to erpaod ;am his already cruatanAiles maws in the warichyklit fashion fidnan). I an the hodaction Manager at Ong Kids] Wok* and brig witted vetth attth climbs as vogue' refthat. Nurnin), hatertarito, Yam GdfaIwit, IrtSrgfri and Allure Atm Lac Brun& hie bsonnis inervatittgly well imam tit ow ISM as taatrlibedIe Iyho we' Web manor raid direct Lathilxi trod& for clients, phottgraphers, ate. Mt. Jenn asc Elmo} aimh mined ere to mixt th 11Xlid appzopriatz models to be Used in an axivetrritaus Calapagit, awl stersecroeney has the otitatandkg ability in manage at stages ci thr- eteripirar wean of prodischrts tbe right model fm a job_ Themfore, the quality n(bl wIt14 is II-Till:Able es lie is able to IthermoCt beaudioul Mad& As a mak he fag becoming one of th,7. pi:kelt:amain cif choice bathe lambkin sod other CtlIltife i =hart:ries. Is my opinkin, Nes Lax Mast is eensty an indhitILIS3 of tatimordinary abiliV in the BM of am and the warilian he will irteurne La the United States cleamiy requites an. indiAridual r x1raordina.-7 abdity tn this tut& )ix, Brunel has %en homistialudiir hsicsra mad recogrited for' his larkftle Wait sad esportise.t rfloanis be tines repdady *mann* tietb. rnoet rtestisbus faehinn uMkfr roubd des worW nth lb nit Magaritir Glenicipoitfun, Nantabsta. Wt. Bruntre amtriimatiaws to major cIin htive sexured hoz a pm-Iliac as ens uf the lesikug dirsobars And tam coordimidars working tad* it is tirm my opinu-all that tbie zesprgirietris and Aut:irs of an internal:ins:31 it cErcetztr, vrbo entiabeiratee with tilt mot distingualied truigazents and attkr.-Vairtg isiLesica, loquire an tnanrici.m) afardy aff ability and aeocurrpl:shnteeits in tri Mr, Jess Lis Thritr,c1, risatiaind an 04 "bats mortis the Vilna &ate% dais lac bond Ina nu* brim hia pberiamansi talent Araeritsa =rim& Flan do mat bums to admit ape WO My gamma& amente. - Faxing** Know montage wit ST P 11111. sit J:‘. 11. •I.ik11 Ø.45S6( VICO Vermont Service Ciotti n Lower Walden Strain Albans, VT 064N-0001 REI 0-iiion-immignsu Visa Petition on belied? of Jests Luc Bros* Dm Mem Madam - Sty name is Nadia Coma sad I am President of Wenger Ntreieh.l I bow 30 YVarS assporience sod lam CuihrWIt t. ia contact with profiesiorials all over do world. A few al my clients in, Niir Elie klagszioe, MI110111. Mow* !aura 3tiap. ugil. v'k.. The Eta, Stsrm. , sod so OIL Aim 4116, I am qualified to comment on Mr. JIM law Brunei's caner as an of direetor of ectracedinisr- ability It is Dot only became of his &demotions or We impenritio body Of work that fashion sdisstisisig sod publishing executives mold the world I..a . choestie O M hm . Brunel's great talent lot their renowned aCCOM Mr. 4lion Luc Brawl is idea an pi300411t0 Imen at furnishing bit chest with tautly dui image of their dram. My perwr.al appreciation of Mr. : ruse! who is saw for ow to r-rJrvrwl his acciarriatians. F'rurn my sgeridtgailte they are certainly !sell coofirmsd. Accordinciv, Mr Brund bill a position to conanrad sizable conipanastion for his wars as comperes to obits in the Winos M. inuesrs minas:Fa as a tartaidabie artist with a personable demeanor precede, him tia is ositstantly ressarchiannO dirreloping stimuistingly now commis for his clients and I bine mine to rily on end tnot Mtn and his ability. OM the tt.n.:rbv. ha celebrated career. Jraft Lar Brullel diginguished himself es oar of SE leading fashion an director in the industry. Kt AIM Lae ilinasi enjoys an extraordias Ft. IlltatiOnSteiri to the acittstw, This gadfly manifests Itself through the besutiful work hr createN. Wee Id* time. Therefore. Jan We Brunei la dauy ens f tiw MOO tabard professionals working is the worki today I look forward to seeing rn.,re' of his work in the future. Sintaisty'goara, 4/64tee-C-t.." Nadia '.sotfrys 111111111111/0 N( 114 1 );; I1 )1\11 leptembet 17. 2014 USCIR Vow* Sono, Coles 73 Lower Walden elms AllAnikeVr 0947114X101 RE- 0.1 titten.inursgrani ,a.a Patton on being of Alan Luc (Mod Omer tieovMsir 1 would Mei* Wend req tifil end unqualified support for the OXIMONlinelY gtatV 04 Wes POW INAMIted b tAz Jaen LW ate* ea the Oen* reknit Produces fee tiortalrorn, I ent quailed to ley that M. Jean Leo Dural It 01 art ditoint ocl Want feted11.21 of the highest caber whose Wyk* emotional end creed* *ice how NNW tots fav no hie prafeeelen Ilmoughote Mt Man ILuc emigre detinguilluei career, he hoe recov, ad a lughti ininnsolvo let of woresstangs POWS end 10ch1evonantli Ni grilk Pelt WO WM riff efamill ties atm kid beautiful citadels that haw appearod ins bat =tanned oraffir.ls in seeta efts nod enthont publicatkina in the Iti. v4110 saves as a tounant ha WNW I ant e awoke' wens* to the ezaaiwo and operational skits of many cmvo wean" puck loniuding art direness and Want coonlInelora, ft la Virsloni irg plenum so risoogolvs Ternentable talon sect achievements of Mr. Jeer Lug lir uml. Hs OVUM ito etal lave I* Amp* mai* from the meet cared" deveiopod creatconcepts and idea I Is hie very unique ability to COMIrruicalsk, via award anal**. WM intended altiee hump of his chants, II is ober that Pk demi LW erlitid*I*41011C1 far beyond evii swami levels lor SUS inetistly by S Wunrili15 Mt% loth lahtili 11* Voprit considanel. Indeed he has worxedsiSi sone of 111710 beit4UVAVII ATM, %Wrt o house.. end eisquinee vt wade; is tr. maw tio.obt met 1 polo 1071 the c'erika 111a vvey bad Is fda prolgastan 1 am 0311fillindy int* Outi tk. Ash Luc ewers repidellon ties a‘chinvsit ingsmeganei staink. tie hss reached a level vitiate toasty leaders me descidet hill, as a Ain Lie Swat's voreanidhwy weer Is at a pert vete dues Is ne taming bee* filncoalp. Uri Widow Solar Tow Pixitraer 141realtors I. 1.11111111 , S hi. oil, VsS 1113 Recommendation Lmter 22/09/ USCIS Vermont Sew= Center 75 Lower WeIdea Street St. /dhows. VT 05479-0001 RE: 0-1 Non-immigrant Visa Petition on behalf of Jean Luc Brunel Dear Sir or Madam: It is an extreme pleasure to write a letter of recommendation for Mr. Jean Luc Brunel. I provide this recommendation based on my knowledgr and experience in the field of modling, due to my established reputation and work in the field as the Vladimir Yudashkin, director of I Mother Agency. Kiev. Ukraine I have known Jean Luc Brunel pmfeanongilly for 5everr4 years thmugh our wink together and, in my opinion, he is an ext*mely talented Individual with superb profettsional reputation. He is an !extraordinarily able coordinator who strives for and attains a level of merit in his wnrk that only a few of his contemporaries meet. He has the abilit3. to recognize the creative vision of his client within the time and budget through hbi careful and thoughtful choice, of model casting combined imktig his meticulous ability in the field. Jean Luc Brunel is a true find to our indusuy. Mere are plenty of or, directors out there, but none with: the depth and quality that Mr. Dninel possesses He is unlike anyone in this industry. sod I expect to see him continue to find great models in his successful career. Someone overflowing with talent as Jean Luc Brine] should be given every opportunity to work in the United States, where he will have the proper venues to showcase his extraordinary talents. Please do not hesitate tv contact me should you he :any questions regarding Ohs matter. Thank you for ynur time and:r6nsideration. 'A. Sincerely, Vladimir Yudash FIG010 141411 gigtifige Otriltiog 4*1141" IIIPM111".411111604. ....I+ r uotrvuak 160/44111PA *Ivo 44 4110.111t*SitS1Kok .4 its • -- • ',V. , Department Of Hatitinirld Sinai* Unitid Stitt** C1Mzmship aid ttroniergition Simon Vonracoll Service C*01iir 30 Illogglice Stritit Sant Abone. vr 1X5470 Ilhombor 011171/41,11 ION IT. SHA 04 rafteartlffrory Ability as an AO Dinectat and VOW Cocsidistatol iscwilue MOW ifemd.ltimit mow '1;0.1Stil Inirt 4111C,:cr t-.1,ip trk s -Ts á%rNriptior riTtiflorl•f;t -•"*-tf-s1L-la- 141 i.s-es," '••••Or, ; cro:ttitLffeli IA0'1** Cate., thematic** IW‘t i.fregIt'''' ;1, / *x1rwe I* tli.viet 'e43, 3 rearelinfol votious tit, /VICK* s t ° „Tn.** OiStit j1/4;r1, qlj by We Grum. has partariffael -gol'acloa Disa. ',4r '.41411'tIrsg 7;01- A,T) 1967. TE4ringtor2 bvil 41 or -41.i :f 111001, 'atCYCItor,•00 t 'VT r Tr.,) -y4,0 ori* e Phe tow supenroa& - snonagoi -',417`i. ir-rfi'vVr‘ "7., the r tric, tr4. left .V411 el'. a slinco.." Cr mi. till' IV II S- " 4 d •_*" I tt',4 1.1,....rorrlcs or inzt.sorl rrogizr,r4:: Pii)+ Wire Core. Parole? 1. t.7.1..el-e 741-.3 ewe, Mt &unto tus • • ,a+ 1/4.4"1"11,E- e Netelt1 v.4)--fn #iuriter. FA,',-r..Ifer) Slane. '-•,*t AstAucx.:1 sSi VS1.1*r#14.', ;.-=-'`'S Ihro:et-rrc, aie warner 04 1rOCe00014 11_ ',TOrnSIP J= Aw.t"ahltelso1P.: erY3010% sipie .1*Ipiletcr 2.222 -t. • - A .AdiAiN.Z.4*rp1*t.,); it II': r-car, pew 1.0 .t: : • „Tit ..tv 1,4 i• yirk7, IA" TA' ;,7+e'S 4-70 Vkittiete;$ 0'40100r- - t 4-.4,7 14 .b.':1!Pt.t MO e,1.111 Oa, _ont4;1 :I ; .I OS g‘Weil Jsi‘i,, PeCereelr 4 r 13.1 TiOr* er t ^,,;kioot, Jet3I coorconc:;1-$; Lents -yd try-, ,..1.1-Nryt+ *Lel- -vor •;1 Meter U, ihe *me —.7,4_01117 Admi MODELWEIK „IONA. It 14 faiklbil `. (I P liv! rii: 11 V% • 1-40-40-14L-- HrbxgBJLy. 2011 DePartment of Homeland Security United Stales Cibzeriship and IrrmigRrion Services Vermont Service Cer 30 ri,c•Jghtor Screer AlbOnS. sir 05478 Re: 0-1 Extraordinary At.iily OS Om Ar- Dircc 4 Or and "alert CQ,crchnotcr behdf of Jear-Li.c Didier .4enn-Renc Brunei To Whom rt AS 0 President .7f Niv_;.c-crk. Mil) *Her submitted in support at rAC2 MOdets Miami, _LC or behalf or Mr Jean Luc Brunel -o work as a* Art Director and gaient Cpowatinotc,. M. &tonal okj jii irtVrTatiOr rc.LIpiftl1i0M, as 0 w;ibio, shategit networker who "-k able -o cultivate expert relationshio management sk tf.s order to conducy tautness in a global ervirorwreng and &inter tucrarive deals. Mr. Brunel nas a long nit2r,, marketrig and adiertic;ng craw fashion campaigns. Inrougtio-it INT twenftf-tive year coreertinn trie fair vi business. Mr. Brune' has developed worcide. exc.usive odelircj COIMOliC campaigns. Some of 1-pese 'rtaior cowneTic campo'cn$ 60 Therm iNitrl sugierrnader toe A..i..-,wrierw.n. t'HA5 VAM kebecca 11017,17-.. CNIStiOri 0101 g'ith Christina Ser........ftrwi(a.?a xitr.Tet Asia! with Mora Belucci, Chanel wylti oirk i VcIf. Ar;., Perf.yjcie mugoor. and CoUc Pertune - P4116010 . s has developed rnaior fashiar, -L:rn-,..)trT3r onct rIfiS Oe., r.pecl cOrnpaigrti Ird:1 elitChnitle cc -mac is r5i the wø tap'5 deSiOr+E.,5 t• 4-h in% Yves Sole aufent. Ctv Chro-4 Dior. GL:c: JOCOlu. In addilion to Mr. Jean Luc brunel cecensive business career os an 4f1CitvAUCli with artistic vision ono crealpve to turn find top fashion models to remesent ir tho United Slat Shmde yap have any questor °boy' tioli ;ear BfL tee tree to corlact rr-c, 4-1 s iy4` rq ci It Prukffl 100 Modehidert. MotiLaiattenlin t a. •Inc; M arc atitiaatinnc, iii rits has helped MC3011 L Pr" OP • DOWITOknl Of Mamba= SOCurlPy United States Olitenerip and lierricration Sertioes VernOnfService Can* 4ouoni0n Street Saint Atm% Sef OSSIS Re; 0-1 bdroordinary Mils as an NI Dec) and Tasont Coolrinatof on behalf ar lean•Iluc Dicsev Iriend.Rene Brunel vinlam maw Concern: As a Proildent of Natalie Model Management. The letter is t..orritteci in surrOart of han models mharTt C. on behalf of Mi. Joon Lt.ic MAW tiC work as an kr Director and IOW Coordnufou Stuns( hoot on interno"onot reputaflon 01 via*. silrotegiC rsenvalter solo Is We to culfkalle expert retallaswiip rnanapernent sials alderto candUct business in a global soviarvneni and broker liJaarrest deals. hir. Brunet has a tong history in rnartotft and adveers,r9 fricVcc carossceons Throughouttik inienly-ave yew career in .the fashion bsilianO14, Mr. &Wei has devolopod worilwida. 110C4filve.:Zilireg end covnetic compotes. Sarre 01i these molar =Work rr Includs4 Rio Them w4Wt supentiodel Ele mcfnerscr_ Pi4AS nth Rebeoco Ron*. Ovidian olor %Intl Civisfina SOITXXvIOOkato. Marcel Airor welt] Monica kW* Civonel Min PaillititlVanhiletenheke. An Peffunlewith Merl Mogkze. and Cacharei Perfume vtith Aldo Bollestia.Mr. Wel hat also artrelaped magi, fashion campaigns and not developed campaigns and iseciudve Catteocis wilt) some of the *NOW, fOO kehiart (*honors PJCh 05 Yves Sarni tautest. Chanel. Chtistion Dior Gucci, Prada. ;and 'AOC .00:001. .3R9Prit1r2, WAIN a' wourtgaroa -4% .:J/1 133riav 11011 Iltr Ert Pi 1 Jti. • 1 lJ J41,11111, pasta nadriallitapplaalr. fleg "‘it- PARLIQ5 uxis PSOAIVII -WO •J'APJ XIDG 810 es Walton to M. Jtar. Luc lituner's extensive &Anew wul kaftam. Meet as on individt.id with °diet AMA and creative latent hat helped hirn 11nd to models '12 woment in the tinied Slates. MOW yeu have any quesions about , *on Luc bunsl luatriiccitions teal free to contact me. SirtrAtitv. Erik Melsons Mem. September re. 2014 USW vermoot Service Cente,,r 75 Lower welder, street St. Albans, Vr osetkosetot RE 0-a Non-immigrant Mae Prtitloo on Wolf of Jean Lac Didier Henri-Ilene Brunel I write this letter in strong support of Mr. Ann Lae Droners applieaton for non-immigrant Visa to this country. I VII currently iiiitittilnIstraitore Unica in Studio It. I have been asked to review the prufeqz,lonal credential; of Ma Brunel, and it is my professional opiniori that Ma Brunet is an Mt Director and Talent Coordinator of eltreOrdinary ability who ranks among the small percentage of !amigo people at yeti top of his field. I have gnu first-hand Mr. Jean Lue's special exper;ise in the including casting. production, comdinatinn, and art direction for &Gott Mr. Brunel is ecnsidered by those its our industry to helan extraordinary creative director talent, particularly for the (add= and related In my personal dealings with Mr. Jean toe Brunel, I found him to be thoroughly pmfe.ssional aid capable of being utilised in connection with. wide range of crestive .aibietl matter on any itailatin$erit. He has the intuitive ability to provide just what's needed In esortTection with any particular creative prom-,3 and possees excellent tic management and operational skills that toner from bis years of experience_ Many people do riot understand that behind MT, sneressful advertising campaign and fashion shoot there me emative men and women who ate making sure that the bvsmess operates efficiently by *Do tdi n 3ti ng different tasks between models. photographers. and managing croative teams. I can honestly say that Mr. Brunel oanlinclaly Roves, himself as an extraordinary Went in hi., field. I offer an unmitigated endorsement for Mr. JIMA Luc Brimel regarding his Visa application as a ixtoon of extraordinary ability. Th'ere is no doubt in my mind that Ma popularity and ability in the field will aid, continue to p per In .ielrs to come reb'' L. !.! ler . 1.1 :" 5115 gi lib/ le IJ5C18 Venni:int *mai Cantu 7$ Lower Welders Street sie. Mows, VT 054'79-000i RIL 0.1 NOrloalseriagreast Vise Prhtaisrs bet-os!: tit Joan Oeir the ere adorn I wee due tilt" se sums support at Ur Aeon Lie Brunets 4tiplickrion So a non latie leatioeri am ceirrints *larking en an Aisait eit Tutu Mtinegime-i, ii lein Angeles. awn epee may ottioduigI the OM f tlx) Wham Im1us1r I ati% rreqn:h 01114 einkeilif* the ciodaratida of olhor mlrettccual4 m the Wel I furl hem asked ea Mg** die psmamJ aredeatede at Mr uteAn l niest It is es, prettattstiol optrliL u. tiegief van iny pateenei atpiabillanet linaeriethleof We lir,Inete taterm. thin WWII **Man director of ractreordanatry abate who ranks einem the prata41 pierettlem at keetin ottitaioionW3 at Ten top of be field. VIII* admire Joan 'tat elnend and 'and vo a rioasumr * war:. terai tkrio a tairtaad pittann. Judatrig b, the high great Inliterlin of the taelperates with s.h.411 he rtaguial: soda. demety I ow not the gully WO into apporiatica his tallow Hia irxhusi sow ell in ow at the iletiego Most putiatif pubficationa reaching litotarly asillians 3i adiatteis tie Ii pI*IICII*ttj binentO for Ms rat ot advvrrnall-4 and rd,iixleti went Nor cantilinittrin hope diem, siitis asWein Intin, 0004 Christian Dii+ haw orcund hint yoliticei as one of the issiting, 11*-Alt Wanton an dervictora *aria* vid3y. Jean Ler Brunet is the consuatunate geldnagoata Iwo it tomes to the an at Illabion and hie walk a aeon ttlec4ayeal U. emits towns Mei esearierics A true wise, be as alistoritteal Co the lealliaattaors of est ebnIni an ow," *ovation. ditheatih Mr Oramai cummunt.is the bobtail 10X110$31163M for ligia Midi. be a fl vetegb the tweet Ur Jan LW MUM IngturAwmitity an .nitIvIduAl of eatroardsnan nem,, iatoratatiorsd anittawvenent and ogitmewiledispient. !ma how soy giaesiitegeas tripluktule tk bun& e entireeetinen abtarv, oteaa* feel bet to tortUttt me Thsakgew fat row ititinailye Min consmittanon. GREORADELSTUDIOS im**041 r neer rook MVP remits wri 10.411110010Manignot•No 9Nobitobir ib, sos4 MIS Voramit8WIdee Omar 110.01,40%biletteit IL Alba" Vt 0$09400 BI: Diliasimeatreestvhis helm am Wallet Joe Um Muni Doak te Madam ?MA WW1' whey to se--ppurt the is applitmloo of Jezo tAx Ortabd so that he maiy ba =lorded 0-1 eittradimity obi* *kw otovs to o:Intinue taexpaiad vim los alritady mammals& moot fie tbe wcetdidde ttahtes indostrj. I ari tbo Ptothavtion Manager at Gm ;Wel Sirtodlos, its1 wand ifititiltaCkaitato ILS VOvitle Raga, MIMArti, hthoureto. Vogue Chronvoi, irStigrei atzl Alum Jaen i410 *mei Iwo booms tocivos mil, mil dem in Our fielf at 601011011 .4110 %IS Irtfalilht, =rasa arml dfrect kaki= models fir clients, phottgriphoms, sit M. host Luc Smog hot o tilde ed el* to aelixt the moat appropriex models to be urriccl. T1-aA athsatikeing eamytalsp, maul aditerruemfly haa the nutria:adios akility to manage all stages of the compirrz ;:ittoreas of product:1i the Tit moda frIr 2 job. Thergfora, guar): otr bkv vs irt mik erottible as tic la We o btsetill I mash, Ma mat he hhot betemoing one of the profestictruils of choice for the fashion m4iy aact atketcream.* athaetri re. rn iny opie Joke Leer Band. is emotya hotilvithol el itStriardloary uhili‘ in the fled of art, sod tbs pamitiela be will anaume in the Ward States dearly =gums am ilaclividuaI oi extrzaariEllgrf ilbraity tn tiilLSea Mt rumel tin Imo inoozotimodly ham Mid iseognized foc; his tudque tab* lad esperdoe. the malelp lis findo neduir wane bk the mot prookkee, hzhion publicati,os amubd *ti worI4 melt to Sao Mworisot, Clasompoltion, Mario, Needuttas bit 114-14era eretribetioon to ata)or dieult iiorye secured km a positioo ow of So leadiog dreftotshdUnit econSzeocrsi weeithig today, ft is aho minim that the reapontataities anti digitsM&n inteMiltintill art &Tartar, -orb° colithumes with the met dietiAgakchett magnum* and siimadoi &obi, rewire an sndivid.tal af estraordiaali Ability and tOffiRvethntiovis aorit /0 Mr. Jeep LUC BMA Iltrooted 0-veboi to *ark it the United eltaiea. Jam Lag Bound grill moo* bring him pbee Was tborAzoodoui nutria_ Mous do not Wade to =we swy poosttors montage um= Lk :Kul,: rimb* ti.. 1. 4, Niale %mot Bewley Centel 75 Lower Walden Street Sr. 4)baaa VT ofieakcpoot 0-1 biondtranignmt Vise Petition co hdialf ethers We Emil Mot Mr Of Madam: Sly roam is, Nadia Ceram end I am Ploadeint of Montage Mrxicis.1 I haw 3o years of cAperienc* and I am con itantty to coma vvith professionals all CIVier the mrld. A few ok my Clients irwlufir Elie Magazine, :A MOWN Ramos, Laura Shop. Oglivii`s.71w ila; Store' —and sti on. A6 Audi, I am tpialified to ammo on Mr. Jean Lc Brunei's weer as 1St director of tnrtraaedioset, ebditl Itissenemly because of his act lunation' or his hopeomioe WO; af work that babies **earthing mid publishing szecutiess mound the: world damns to abbe Mr. Brinier, greet Wan for their lesluvrileti accanrits. Mr. Jeen Log Brunel is also an absolute apart et Webbing his chaps with e: wily the image of their deals*. My ptirtonutl appreciation of Ur. Brunel mem fe meg foe or to compn-hend his acclamations. Proien my they MITT certainly well conibund Meardiewiy, Mr Brunel le In to connared liaatsie compennetion for hie WO rk es compares to in the buslacee Itr. *ir! reputatIon ala fonnidable ;nibs: with a perstxtabla deaior precedes him. He in constantly researriting end developing stintu tingly rw alaSipti for his disco sad I h4we come to My on and trustMm and his ability. Ow the coarse of his celebrated meet. Jean Luc Brunel lhaa ablinguidted himself as tor of the Wats tednon art dixeetorsi in the inanery. Mt. hut Lot Snail er,Juys soexbaordioar, relationship to the This quality resoliesb itseN *mash the bamatifid work ar ereittets, time afttx Woe. Therefore, Joao bat Sruad is dimly otse of thr most talented peafestiaanis working in the world today. I look forward to meek* vorr of ILiaw the future. glinenteb• own, Media Como' 11111111111111, NORDS1'1?()M Ssatember 17. 2014 MSC* Vermont Salvias Cedar 78 Loavatildilden Mist Una"VT03479-0001 SE; 061 Itonminagrant Val Annan an Whit of loan UM &Una OM Sir it Madam tumid gm IQ *Mid mri NA and tirigusalled supped for the adrasidinaly *bay Gil visa Podflort itidneid 11,V Ms, Joan Lua Wand Am the UM? NOM Piadister &iv $ocdWom I am uwidnord to say the Mt AMP Luc finaid is an art *edits( and talent scsadinailar at P4 highsv Whose Isclintain excalionce and creation vista have Wald hall tit the lap ri his peolassion. Thropohnia Mr .liam L une* dei5nguisihed resi, he n riicolvoti a high17 hiptiklahlel id al ainfessiono‘ WW1 nr4 ediwriremeni* i Pie Peg tOw YeiniPh Braid Us *tot, Ind beautiful modals that haw appeared Ins list accfittir,en projects in Mina at Ile oast tenkvaid publications in the wtd, which swats as a tommunt to ids I arta aoratieni ninon ba the amine and aperalianal skits of iftley C171ankiV dnecbori people, imbibe an diactirs and talent catatilnassta. It is Shirsdora tiv piestais se micalantwe tha nensaliabis %dant and adVavarrisots of Mr. Joan Luc HT WWI 1, Kt 1111•40011 fiGhierkae the slitanaest wails Mate the teed cared*, dwireioped creative -concepts aril MN* 111 is his *rely unique abilityto eennuriCele„ me lareiii analysis, the intended =eft onSids90 of he onsets. Si. obier that M. Jim Luc ening* teicastoo fly onYclId the swags Mods trx this Industry by it* slum** MOM VIM wt& Ns work consiciered Initssd, no hill IVOrkta 110010 Of me bootiutorm wows Won 11011.01L Sad insgatinse In es wand it is wIllitaA a doubt thst I blisos an Op the -Ro& ce fat way bat in his prolasstin I an tallfidaltily Mit* that Mr. Assn Luc Owner's %lavish:in nu unwed inisinalkend *dirs. iirt his reactod s level where industry Indere now describe hilit as a "star. glawi tun aruners areVaordiruity arm it it a pooisA oPierteilleiret Nina timing tea- Liza MaelOW Senior Toiled Pradister nornornns %it silkl fluo Recommendation Leiter 22/09114 USCIS Vermont Service Center 73 Lower VieMen Street St. ,Albtoss. VT 05479-0001 RH. 0-1 Non-immigrant Visa Petition on behalf of Jean 1.1w Brunel Dear Sir or Madam: It is an extreme pleasure to write a letter of recommendation for Mr. Jean Luc Brim'. I provide this recommendation based on my knowledge and experience in the field of modeling, due to my established reputation and work In the field as the Vladimir leurtashkir, director of I Mother Agency. Kiev. Ukraine I have known Jean Luc Brunel profelmonally for several, years through cur work together and, an my opinion, he is an extr,inely talented Individual with superb proiesstonal reputation. Hi s an :extraordinarily able coordinator who strives for and attains a level of merit in his work that only a few of his contemporaries meet. He has the ability to recognise the creative vision of his client within the ton and budget through his careful and thoughtful choice of model caning combined with his meticulous ability in the field. Jean Luc Brunel si true find in our industry. There are plenty of ar directors out there, but none with the depth and quality that Mr. Brunei possesses He is unlike anyone in this industry, and I expect to see him continue to find great modes in his auccessilli career. Someone overflowing with talent as Jean lAre Brunel should be given every opportunity to work in the. United States where he will have the proper venues t.,1 showcase his extraordinary talents. Please do not hesitate to contact me should yists have any questions regarding this matter. Thank you tor rout tinge and c6nsideration. Sincerely, Vladimir Yudat h FiGaro PIIII 1111116C09P 11,11141111 11101047 trya WIOwe,hk0.6Aok 4,4 KW MP*, 11~111141P0 1W4.11111 '14. 4144-11*1 1114014 .4 .114 • 1. • 111.0Z4440111.7 - Deportmant Sseurity Unibed StainCitinereship ailed forensigration Sorricias Vermont torticoeshease 30 Houghton &mot $ad Mews. VT 0847$ Number 1517141S M1?, Nt4 Zer fotboxeftary Maly es eh Altciroictoir alw$ Talent Coorditiallok col brawl or itooltHisec ado Notif-no &woe fn. Ct .4,t•=, or:qtr 4,1* 011r*Ciat t?i," L-,:tpi ti,titiOrt AI 1C#490 : 14.11CC191-4, 4.;71'..„1 ,1:T out" be i•Necits$241 ion*. the earipeis itemeidlet1 ' ek.4,•1,ei ix?! 4.ist th3 cirdi 190,11014000 0040‘411!,..,p+-)- ,Y)Odrotti 4,4,4421100P id 470? i,ti.. Ntija feted tip Pa aNnelf has r:ort_nrinai rc...,1w-14.,111 967, T.,A1.9 i'Ort Co, volit ;4'; Of ,:!..lt"'t:;( MOOG Pc.,;7:en7;r.`r-c t tblo Hi I t'.'WeriPi ,7•41.110)011. e tot...? gyfact,-;rniii,•rn:7rine4.1 07C'Slor 1777V;',..1;`, fIrritt .1** 19.117s 1nP SOitd '474104" r 400-110 111,10 yew e-7.4 finor - 41, ' °Y'j I1 11,,:rarrcz at $30-i or SZ,V7 f7..1 V09„:1, 1410 fiOrleir vere Core. Some/ Isq6ing. 2res ew rr Mr, el'Utiel t-‘21, r"-.1!!! ItP• a '; %.":411t1 ISUCt/ t4,:fitet SINCIten v-torttO Eit401 1•Vs34fStk CI-4411iro Se ovitrarea.ese warelev's as OPOIC041060 - 2 rtei. covet rroasi.-. *hi, wow). cocoocro 4 • i r,v20-. • f. 3rid spa , ?Dory ‘j few t ot • IC, jt.0 t .40 e419400: .1WP0Z0Fir WL ,A,q, 10011r3 •rtli ovone," iPQ giocip.(-yrywArt t• tytut '-;fa "Arai+ i.ftiftrlut, r-***f-d ILTIt'fr-•-t r 001V1 firrelertteii jt • r*.:11;) z 4- Af'," 6a.e .jr* cV r 5*-7.N.; *at- nti tr-r, L r t1):. heat 4, resiesero iht ,ecs 'es • "0%.cr Cs 0 ‘11:74r-' x/eOlk. '+oftakil.-. • I 106. _ — ; MODELWERK T401 ;AN I tiambil .6o4 I I .';,,41c 11460f%, El "Um ta !I • III 11!' Alaxklvorli, Hamburg 8 July. 2014 Deporfrnenl of Homeland Securiiv United Slates Citizenship and kr -nigrah:on Services Vermont Service Center 30 H.D3.,ightorl Street S4011 Albans. VI 05478 Re: 0-1 Extraordinary Atitily as an Ar Dire cc and 'latent Cocrdinatcr :n behalf of Jr-Luc Didier -.enri-Reno bum! To Whom 'I May Conce—i As a P•35ideril of Morietwcrk. his letter is suorriited in suoper of tAC2 Models Miami. ,.1.0 or behalf of Mr. Jear. is Brunel -0 work as or Art Director and Talent Coordinatc,, Mr Brunel -.olds an 41e-iatIonal repufallor as a visible e'alegic netwomer who 'I able "o cultivate expert relationship management *Ns order to conduce business in a global er.vronmen° and brocr-, ocrarive deals. Mr. Brunel Ms a long listory mariKe-rig and ClagefilV lg rreitOf fashion campaigns. Throughc..at rim twertiN-five year COreeri me folg-:cn business. Mr. Brune has developea wor<twicia Oxc.usve triodclirci 3,vti cosmetic campaigns. Some of Iheie -notor cosmeric carnpc.\;ns include. Blo Them l with supermodet uie rvic'.Thersor.. PHA w w.eklecca hrorm-$. Christian Dior with Ctulshns,i seinCtiViCiVi<ay0 Margret Asiqr with Monica Meucci. Chariot with Plaiiir i Vf RicAervie.irr, ofkrge PsriJone rth Thery Mugler. and Cacho(' ",erturne wiN ' t. fiallestra. Mr..3!7+Jrpe has alsr., developed major fashion z.:;_;rr,-,):4ris ono Irios icsevt rped campaigrs ord exclusrve cavracts -no of the fast- ior 477, Such rii Yvel 50011 toff:y-0. Chondi Clristion Dor. 4000M. ;In addition to Mr. Jean Lur Brunel s extor.iive bijsinev; comer as Ws indimtua witn artistic vfl ono creoNe to him Nnd top fashion models tn reoresent Ir the United St at Should you have Ony Questions °boil Jeor _uc Nnei feet tree to contact me. PreSictene4° au " ;e' 1') tviodekverk \filiiiviarctilitr I;mill I Marc otaltationq. Its nh ha s helped I wr...110.,;:-.V-ce-is meeti,v vesv-auv Aly 11.70'4 01001meni el Nontstext Sec" United Motes Myer WO and intrnigrolion Solviass Vermont Service Cartier 30 Havgision Sires' Saint Alban rer 05011 Re: 0-1 Etertxvcinary 103110 as cn Ad Meek/ Toient Coordinator on behalf at Jean-Luc Cr tlerwiliene Brunei TO Silvan tt may Concern: As a President al fiataBe PAWNS Management tvi tenet is fitornoted in waiscst es mC2 models mzrr.. LIC or Denott ot mi. Jim Luc asurffaP ft wok as an Art Director arid Tamen, Coadnalar. sat Brunei hold; co ritemotienol repitallon CtS oVISIbk. CkCitegiC nelerotter who is obse to cullivase evert fosalionsila management skill cedar 10 conteXt Dullness Via giatal ereinxweerd avi tvolier luoratree deals. hir inter has 0 long testacy in maiming and atIvertiong /Tao ladian campaigns Tryoughok.i his twerriplive yew career In lee fashion bushes& us. Brunei has developed vitifft•vidt ISCS:StvisrdI crld cosmetic comp:Ion" Sone of these maior casnedIc ccimpolcrs include; o Therm wen eiparritodel Be mcPowno4 f41104,S with RebeCco kw*. Chilean OW talith Christina Semonnorskom Margret Asia viiith Monica Meucci, Monet Win Potticio Von Rickonheim. Angel Pedume with Triseny hissfer. and Cot:hotel Parikene VAN' Aldo Sokoto. S. &run& has do, demaidPad rnalor fashicel campaigns cind has clvelOped campaigns end attar** contacts wilh some of the rvoltCrS 10p koshiCal clessgnors SuCh cIS Yves ScIrd sward. Chanei. Christian Dict Gucci Prado. ond Marc .i0c0Os. ji&.4-ji-ntaro MAIM Ur lorittlAta.13 ailla a /a, 407.3 V.1011 'Areek44 lair 3 an Psi arm. .11. psi Jssm, puts netagrelopplal,_ "WY., nalss aarn-cdath. Qin 1,414X0iLIS241, & PARLIKSS IONA Lads PARSAW forts a 16 nal gixo ci• A en WOW to tic Joan Lac guide's eiders*. bLisifiele MOW Cs an incilvkilai with *MSc Alm eV ONIelvetoiu,i4 1161 MOW Plint MO top tookiart elcAseis so nsprissont et Ms tinted Slates- Mead 'Mu hove any gumboils about Mr. Man toe Slung feet iree lo cardact mu, ii Vermont Service Center Attn: Premium Processing Unit 30 Houghton Street St. Albans, Vermont 06478-2399 Facsimile Transmission To: LUIS FONT Cirtzenshi and Services Fax Number: 19542414272 Number of pages including cover: Date: September 6, 2014 From: Email: Receipt Number: Vermont Service Center — Premiirn Processing Unit Fax Number: W2-288-1778 W.; PREMIUM PROCESSINGODHS GOV Phone: 1-865-315-5718 Attached you will find a copy of cu decision concerning your case The original decrsion will follow via mail If eligible to appeal our decision appeal forms mil be included —Important—Important-4'lmportant—Important-** If responding to a Request fa Evidence or !lent to Derry. ensure you include a copy of the decision immediately following your cover page and indicate the total number of pages included with your response Please include the case receipt number (e g EAC01 000 12345) with all correspondence Ensure when responding to this request that you fax your response to our NEW FAX NUMBER - B02-238-1778 if you wish to mail a response, it must be sent to the VSC Premiirn Processing Unit at 30 Houghton Street, St Albans, VT 05478-2399 Do not send your response to the 75 Lower Weiden Street address, as that will cause delays and will not restart the premium processing clock until the response is identified as a premium processing case Title 8 CFR Section 103 2(b)(11) Submission of evidence in response to a Service request states All evidence subenMed in response to a Service request must be alornitted at one time The submission of only some or the requested evidence will be considered a request for a decrsicn based on the record This communcabon a ritended far the sole use of the individual to whom it is addressed and may contain inforrnabon that a prmleged confidential and exempt Iran disclosure under applicable law If the reac, of thrs corrimunration is riot the rlended recipen1 or the employee or agent for delvering the communication to the intended recluienl you are hereby netted that any drssernrialion distrkiuton or copyrig of the communication may be strrtry prohbled if you received this comrnunrcation ri error please notty the sender arTracirately by telephone arid return the communicator alume address above use Lin led Slales Postal Servre Thank you www.uscis.gov U S Department of Homeland Security U S Citizenship and Immigration Serviirs Nonce ot Action Page I of 4 Applicant/PetItioner A # Appncation /Pent ;on Petition For A Nontninitp,rarit Worker Minn 'a Notice Date August /6 1014 Response due by November 21, 2014 MC2 MODELS MIAMI LL( LUIS FONT FONT LAW GROUP PA .1440 HOLLYWOOD Ita 511 41j HOLLYWOOD IL ,1,1021 1-4 At. I 4Z. Z55(iN().-1 -EAC14/255u803 Applicant/Pelitiotier MC2 MODELS MIAMI LLC beneficiary BRUNEL JEAN LUC Receipt Number EACI4//550803(II 19) WVIUM PROCESSING IMPORTANT THIS NOTICE CONTAINS YOUR UNIQUE NUMBER AND MUST BE SUBMITTED IN TliE ORIGINAL WITH ITtE REQUESTED EVIDENCE 1 U S Citizenship and Immigration Senaces iUSC1S) requires additional evidence to process your form Incase provide the evidence listed on the attached pagets) For Form 1-129 only, if you are requesting consulateembassy notdication, provide the requested evidence in duplicate 2 Your respe must be received in this office on or before NoNeinbef 11 1014 Please note the required deadline for providing a response to this Request for Evidence The deadline reflects the mzumum period for responding to this RFE HilWetiet, since many immigration benefits are time sensitive, you are encouraged to respond to this request as early as possible but no later than the date provided on the request You will not be granted an extension of time to submit the requested evidence 3 You must submit all requested evidence at the same time If you submit only some of the requested evidence, L'SCIS will consider it a request for a decision on the record [8 ('FR 103 2ib1t II ii 4 You will be notified separately about any other applications or petitions you have filed 5 From the date this office receives your resubmission, a minimum of 14 days will be required to process your form If you have not heard from LISCIS within 30 days, you may contact this office at r866) 3[5-5118 6 Mad this nonce and your response to VSC heiruuni Pressing Vermont Semce Center 30 Houghton Street Si Alb-ans VT 05478-2390 vs- premium piote”iniatihs Qv U S Department of Hornefrind Security U S Citi2enship tind IMrnigrdtion Servites Nonce of Action Pagc 2 of 4 EAC14ZZ550803 (!jig! ___________________ Responses flor Preini um Processing cases only) may beloxed to (8Q2) 488-1778 Include a copy al this notice Thee inail address may only be used for inquiries Do not send responses to thee mail address I. I d9 0- Ili Extraordinary Ability in the Arts 1 ou MCZ Models Miami LLC hied Form I 1Z9 Fetilion lor Nonintringrant Worker seeking 0 lit MII)Ift11111gRI11 classification liar Jean Luc Brunel as an Art Director / 'latent Coordinator The 0 .113 classification applies to individuals with extraordinary ability in the arts The individual must have sustained national or international acclaim His or her achievements must be in the tiekl of expertise and show a record 01 prominence in his or her lipid 1G process your pennon and determine ml the beneficiary is eligible additional information is required 1 his request provides suggested evidence that you may submit to satisfy each requested nern You may Submit one some or all ol these alenis Submit none at the suggested items and instead submit other evidence to sa1is4 the request Explain how the evidence in the record already establishes eligibility Request a decision based on the Ter071 Note poweveLthal, yQUIff ff5PPMfble lqr PrOviding evidence thatlksi shows thaLyo and the pIrtie ipstin_pplitigh meet all requirements Evidence must show that all parties were eligible for the requested benefit when you filed Form I 149 General Requirements Inr All 0 Nomintrugrant Petitions In general petitions seeking 0 nonimmigrant classification must include Copies of ontracts A description ol the competitionts) event (st or pertormance(s) and At least one consultation To saint, these requirements you submitted - Your letter in support ol the petition and Peer letters in support al the beneficiary trom Claudia Muloto and Alla Amaniova Beneficiary s Previous 0 - 1 Status Petitions involving an extension al status lor a beneticiary that has previously been gt al.te (I 0 1 nommringrant status may he given deference however U S Citizenship and Immigration Services (USC1S) is authorized to question extension petitions when a substantial change in circumstances occurs when relevant lads change lrom one petition to another or when the prior approval may have been based on gross USCIS error )ou militate that the benenciary was previously granted 0.1 nonimmigrant status with your company The details of the beneliciary s previous employment with your company are not documented in the instant petition A review of the evidence submitted indicates that it the beneficiary's role within your organization has remained unchanged the previous petition may have been approved in error. as the list ol duties you provided do not appear to descnbe a FOR oFFKI USE ONLY Form I 797 (8/03/90) Y U $ DeparlInciit of HOrrtland Security U S Citizenship and Immigration Servic es Notice of Acnoti Page 3 of 4 MC14/4550803(1 I Z91 position in the arts In addition DO evidence has been submitted to support your claim that the beneficiary is an individual who has extraonlinary ability In the ails that has been demonstrated by sustained national or international acclaim Yu have documented the beneficiary s past success in the business of tot ming and operation modeling agencies but this evidence points to the benetiriarys ability on the field of business not the arts Therelore you are asked to comply with the following Contracts Pennons seeking 0 nonimmigrant classiftratton must include a copy ol a contract between the beneficiary and either the petitioner or the Pmpioyer II a wniten contract does not exist you may submit a detailed summary of the terms 01 the oral agreement between the beneficiary and either the petitioner or the employer You did not submit any evuleme lot this requitement You may still submit evidence to satisfy it Wniten COniraciS or the summary of the Innis of an oral agreement must specilv the terms and conditions ol the employment or services They must Specify the wage altered antl explain the terms and conditions under which the benetictary will pertorm these services, and - Detail any additional services provided Nature of the Event or Engagement 'Jou must provide an explanation of the competition event or pertomiance in which the N./IMP-My will participate An event means an activity surh as a scientific project conlerenre convention lecture senes academic year or engagement during the requested validity period The description you submitted is insufficient In your latter you list the duties at the proffered position as 10'SpOnS11)1e 101 overseemg the artistic aspects at the agency (select the images placed on the model, business cards ,:nd in their porilohos) Coordinate the pairing of models with photographers Direct the marketing of models to chents Travel around the world 10 tint-Over new Ulm( and 10 sign them with MC Z Models and Establish relationships with agencies around the world and negotiate representation agreements The duties you descnbe appear to relate exclusive!) to the maintenance ot business cpvrations of a modeling agency As previously stated you have thxumented the beneficialy s past success in forming arid operating modelmg agencies however this e kicience points to the beneficiary s ability in the held 01 business not the ails It is not evident therelore that the 0 18 noturturagrant classification is appropriate In the inSlanl case Regulations define the 'arts" as any held of creative activity or endeavor such as but not limited to line arts visual arts culinary arts and perfomung arts Ahens engaged in the held of arts include not only the princtpal motors and performers but other essential persons such as hut not limited 10 directors Set designers lighting designers sound designers choreographers choreologists conductors orchestrators coaches arrangers musical supervisors costume FOR LARK £ US/ ()NIA Form I 797 (/O3/9O) /* If 11 Deo twin of Homeland Sr-runty U S Citizenship (ind immigration Servii es Notice of Action Page 4 of 4 MC14 a 550803(11/9) ___________________________________________________________________________________ designers makeup artists flight masters, stage technicians. and animal trainers The duties you describe correspond to business anti management fUTIMOTIS DOI to a position In the arts Before adiuthcation of your petition can proceed this discrepancy must be resolved You may still submit evidence to sanity this requirement The desknplion must include An explanation of the nature of the events or activities. Beginning and ending dates at the events or activities. and A copy of any itinerary that shows dates name(s) ot the employer (s) and location of the event (s) You mot establish that the proffered position qualifies as a position in the arts as described above Any and all claims must be Why supported by documentary evidence FUR ,FFP.. I USE uNLI Form 1797 (8/03/90) Y FONT LAW GROUP, P.A. 3440 Hollywood Boulevard, Suite 415 Hollywood, FL 33021 Tel.: (954) 241-4271 Fax: (954) 241-4272 November 3. 2014 Director United States Citizenship& Immigration Services Vermont Service Center 75 Lower Welden Street Saint Albans. VT 05479 RE. NOTIFICATION OF WITHDRAWAL OF 1-129 PETITION WITHOUT PREJUDICE BY PETITIONER EAC-14-225-50803 Petitioner: MC2 MODELS MIAMI LI.0 Beneficiary: JEAN LUC DINER HENRI RENE BRUNEL Dear Sir/Madam: Please be advised that this office represents the above referenced petitioner and beneficiary in this immigration matter and a G-28 from our office is on file. THE PETITIONER, MC2 MODELS MIAMI LLC HEREBY NOTIFIES USC1S THAT IT WISHES TO WITHDRAW 1-129 0-1 PETITION #EAC-14-225-50803. The petitioner requests withdrawal of this 1-129 petition without prejudice. Please note this request for the record in the above referenced case. We respectfully request that you send us verification of this withdrawal pursuant to the regulations contained in 8 C.F.R. Sec. 103.2 (h) (15). Kindly send our office a written verification of this withdrawal located at: Font Law Group. P.A. 3440 Hollywood Boulevard. Suite 415 Hollywood. FL 33021 Thank you tbr your attention to this matter. ---- Original message From: Jeff Fuller Date: 11/12/2014 11:49 (GMT-05:00) To: Jean Luc Brunel Subject: RE: New York Jean Luc, I am really sorry you feel so bad and I know it has been a mental and psychological frustration. As you know I chose to partner with you due to your reputation in the business for being a top scout and developing a couple world class agencies in the past. I knew what you could bring and I knew what I could bring and contribute and I thought it would be a great partnership. Clearly, I never expected to have the level of challenges we have had recruiting new models over the last several years. I could have never foreseen the problem of your friendship with Jeffrey Epstein turning into the situation it has where you are seen as guilty by association when you have never done anything or even been convicted of a crime. Frankly, I don't understand the necessity for Conchita Sarnoff or anyone else to continue to defame your name and MC2 by association. It is true that we constantly have to justify ourselves when recruiting new models. The industry is extremely competitive and as a parent myself if faced by the same information and having to make a tough decision between too agencies I would not pick MC2 if I saw the article online about you. You have to read closely to see there is not a charge against you but the implication is strong and of course now days everyone believes everything they read online even more than the traditional newspapers of the past. I know you are now feeling like a liability to MC2. But you personally are not a liability to MC2 but this published information online is a liability. We are not a large enough company, nor do we have the capacity to fight this on a global level. On a google search in America we have put enough information online to not have it popping up so blatantly but we have no controls over the rest of the world or the finances to control this situation and we are affected as every major model agency recruits it's best models from all the various countries abroad. This has stunted our growth and our billing over the past 6 or 7 years. In fact, we do not even know who avoids us based on finding this information. I have been surprised how challenging it is for us to grow due to this problem. I have also had a tremendous amount of worries from our clients that we are vendors for that are large American corporations likes Kohls, JC Penney, Sears, Nordstrom, Target, Neiman Marcus, Macys, Saks, Belk, and so forth that require vendor agreements and for us to be considered an upstanding company. It really worries me as some of those companies have disassociated themselves from what EXHIBIT K they believe to be questionable companies. So far that has not been a problem but it could come up in the future. The fact that you are requested for so many scouting events in various countries and cannot promote yourself properly to promote MC2 in the press due this problem has it's own sent of repercussions in terms of our global branding. In short, it has had a terrible effect on MC2 all around. I really urge you to solve this problem and get this removed from the internet so we can grow for the future. I've fought for MC2 and been extremely loyal but I must confess that I have even been feeling inadequate and questioning my ability as the leader of the organization. I can only attribute the fact that we have scraped by in the recession and barely survived in the past to your hard work, my hard work, and the tenacity of both of us combined. I can only imagine that if I am feeling inadequate and frustrated over a lack of growth of our company that you must feel even worse as you have had much greater success in your career and have operated at much higher standards in our industry in all areas from reputation, respect, admiration and monetary gains. I can even surmise you are probably feeling a level of depression and I have seen it in your highs and lows and when you have voiced your frustration. While I know you well and recognize you don't really go for the kind of advice I will offer; however, I think you should at least speak to someone neutral such as a therapist or a counselor to let your frustrations out and if you don't feel better and are still feeling down or depressed to see a medical doctor for your condition. You are such a positive person I hate to see you fighting what you feel is a hopeless battle. It is not hopeless you just need find a way to get that information offline and begin to repair your reputation. In the end I am afraid the damages are a lot more than you realize but let's keep fighting and moving forward as we have no choice. Thanks, Jeff Jeff Fuller President MC2 Model Management USA EXHIBIT K FROM: JACQUIE JOHNSON <.J.JOIINSONaiRRA-LAW.( 'OM> DATE: SEPTEMBER 18, 2009 3:57:44 PM EDT TO: "'TAMAQTKUDNIANLAW.COM" <TAM.VerTKUDMANLAW.COM> CC: "BRADLEY J. EDWARDS" <BEDWARDS4RRA-LAW.CONI> SUBJECT: EPSTEIN - DEPO OF JEAN WC BRITHNEL We have confirmation for Mr. Bruhners deposition on 11/3. We will commence at 10:00 a.m. if that is ok with you. Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeldt Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale, FL 33301 Telephone 954 315 7264 Fax 954 527 8663 JiohnsonOrra-law.com EXHIBIT L ---Original Message— From: Tama Beth Kudman <tama@tkudmanlaw.corn> Date: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <2jeanluc@gmail.com> Subject: Re: Hi >All depos are cancelled for now. A letter confirming this is being >Sent out today. We have no idea how long this shall delay things. I'll >let Michael know. > >Sent from my iPhone >Tama Beth Kudman EXHIBIT M From: "Dr. Royce Jalazo" <dynamicbeh@gmail.com> To: joetitone708@comcast.net Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an outpatient individual psychotherapy session with me on 12/12/14. Thank you, Royce N. Jalazo, Psy.D. Licensed Psychologist Dynamic Behavioral Consulting a DBA of Dr. Royce Jalazo, P.A. 1975 E. Sunrise Blvd., Suite 532 Ft. Lauderdale, FL 33304 Direct (With Voicemail): 954-232-7092 Toll Free Fax: 888-236-6979 or 954-208-3400 E-mail: DvnamicBeh@qmail.com Website: www.DynamicBeh.com EXHIBIT N jtosa...i60 SCISkIll tWNIib Scuion rrred Or.EessedSad _Pe-,c nteim J'affit°PriAt I-1rg DIC T110,1: an 4. tit.* di Mot !SMik 'IMMORAL L, t'ONSULTING etychii*enempy_______yasuahom_____________entiskillatiterws Clio* Strike skin #: MOOD. ras ehrfsr LhInv LaNyrnic _$eztieliAnt ficiic106 _____ Otivrt fTpn AFFECT; 4,Act-A ANyurmitc Waited RI:sin:Jed neat 1Prusevis Idenandtwit,istetinit Dynamic 4wIir Cossaidgeg 1P5L Semis* Blvd, Wilt 512 Litseeniske awl& 33304.1413 Data T 1s4 TH FR SASH Tim lh I S n.ns. oir: ILIIL p.sti. Donstlan:O tninuto Apegrvuy-- sligirly Intense ter:Itirczt I E Ch4cnuuu mteounk aPP'). LIZAAir ifILL48, Was pasiezt Neirovwf tor psyciturg- evaltsaton amitr-ggni-ki end in prm-rthrciproSotrYrt- me:41-a4:ign Fir,',113-2:11.11 te Frnent!, mon-vornplive 0 V EDI annrnctit- Is ptteci ctirnani taking ps)vbx,-*E rrodicationt: DD ii, Pcenc: Cornplisat N'A a N Cartrs--4 NIOTIVATI(YI FOR TRE 4,TMENTtriaNGE:__________ 14J14, inotimod fli3u,I,bty m*1m Dii,rt DISPOSITKIN: o Conmlur Ttvacalcnt Termitaiten treetmex 0Reef le 1 Ottl-et: ot 04A.•.,.11., LAM 11:44444-L4e . iteyeeN Imo, Pt) ID Immo Fsocsaistaz PY1611 EXHIBIT 0 Ussonatinsed COMPOSITE EXHIBIT P MEDICAL HISTORY tagarifil°4411.1"." ki*/ • *re eg4 Wel it Wel W4,1111, " }I: ft " 0.41 6" • 44-0 teid.11.601401011%"!‘ • - pa I P. 1'P e. .6i6411: 14444: W11 10+66..0* la IOW& SA •pf ;La UP+ 4 Wylie 44,4 410 • • .ab • IVA ;' Pa On I. 4;1 ij 11'41-7-w4" 41 Vol /0 44-4P4`41.4-1 1111444111 1f imt anion minuswiq 4511151(1I1Oist•i+.44)-4rIpiv5 se ) /144.10" m.40.n• 0•04m1"4eulte — .4eir — WOW,-- at" , 00 Inn LIMO ( I hirim, V WOW (.1M2111M Sb 111$1.41)1111,1JUS:01..0111.1 (WO titnarattriuntsit • MO? AN' a c.744.• • + V,T1 .. .444 4,a it tirftr+11411,14.4.4,1 I VU44114x-r•ilv.• 1-131, 11 I I "ARO •414.4.4 '141444 PIP'04411110$141114111.0.1' Iii 1."41c+11411 1 444,14.141N 41.0144.4+4 la 4111,, I I-N.114411 WI I - 44'4 II 411% goingteuttnamo 1VIldSOH MN NH fsowEntnatli5thav BNH HOSPITAL1NR 31 soict lava (Bangkok Ntaing Homo Hospital) MR. JEAN - LUC BRUNEL Prozac (20 Mg) Capsule # Take 1 Capsule Once Daily After Breakfast 0141221248 02/12/2014 135,53 Tel. 02.680-2700 Fax. 02432-0S17-9 wend ON tnwEran BNH H .c, „„ (Bangkok Nursing MR. JEAN LU Rivotril (2 Take 1 Tablet Once Daily Before (It May Cause Dr EXHIBIT Q EscortAgeosy. ft/Or =doling money owriat ion. Luc &t4nai who covana Oat LIC2 meactcy in Miami Sawn, &wort Mho Woe to Ingot and firml lhamaehitia ontinarad ta a itvAnclarwalbola:644/as.yi ottgoituido-llorda abo-ikialapaltorgtoliancioloricia-1, filic011- 1410,Cyl- triggir gelEscort In Floctio Thri mist popular grown-up 014 awed inmitia %item topottad by WOriv. .. Fiend') =doling loamy oovnot Jean. Luc Brunei, who co-owat tha MC2 nsawy 4:acv-tiLeAtIcrect‘arkai fl ofgrirjat- -Mi4.,Gitrointiaa-abc-sta3.apa yi.tagigal S ascott in rionda NovtUnAkinagijings1Ert Sinew- laritkils *ice inroad, Moict radio niativinet drop Icktilas from , French modeling agency nwriet ilamseptuo lininet who ork-awna Intt14102 agancy inP 11714 air Moors ttbc- scS-opit 7$,4~,4-Drinotilvmhuni-be,410 _ • 0%60.03 Ii1heara-abc4el$, apayi itrboirito- rniekraik-bnalcry 'mar%) d4rs.or PAWNoftwakin nal. Mate Iacono ant legitimate prolassiortniti Rand) matialtig ;loamy &Arno joan,Luic Isruniol./Alho crpoing ft* AiC2 hrjoino hi ?Atom 004‘ch oticesite.;044mettA" -10 orgickrea, vvitotium yi worms Inc-actin" 5imjlig I - ;.-e- • 0.J 41.,4411, '" ' uvehat J.gø Lta 4%1M11, Vriio colymta lila MC2 Agart4m libittni fiaach aboa Oar Yea i Citillo Florida Etiebeil , 41itytive 9,01 eirtp 114101114)110rfv5ilr.irI Yt, 11 .1`., rttwi • • t iiiiLsOe lit ESCQL1-1 miseak bend., Illagida *scans in. No Strinps Atsactioa c reni-41 friothoit%0 eifirrtiv aft on-owniv A4C2 army - 1044as„ rdige liozwpet g1L =gm. owe; fi tda. gaiong EXHIBIT Q http://www.politico.com/blogsiunder-the-radar/2014/12/court-filing-levels-sex-claims-at- alan-dershowitz-200495.html Woman who sued convicted billionaire over sex abuse levels claims at his friends By JOSH GERSTEIN I 12/31/14 6:38 PM EST A woman allegedly kept as a sex slave by politically-connected billionaire investor Jeffrey Epstein, who went to jail for having sex with underaged girls, is accusing several prominent friends of the financier of having taken part in the debauchery, according to a new court filing. The woman—referred to in court papers as Jane Doe #3—leveled the allegations Tuesday against Harvard Law School professor Alan Dershowitz and Britain's Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel. Dershowitz flatly denied the claims about him Wednesday in an interview with POLITICO. It's totally, unequivocally and completely false," the celebrated attorney said. A spokesman for Prince Andrew denied the allegations Friday, while a lawyer who handled related matters for Maxwell did not respond to an e-mail seeking comment. Representatives of Brunel's modeling firm also did not reply to e-mail messages. The accusations came in a long-running lawsuit charging federal prosecutors in Florida with violating a victims-rights law by failing to consult with Epstein's victims before signing off on a plea deal. That pact ruled out any federal prosecution of the investor, who agreed to plead guilty to two state prostitution-related felony charges. Lawyers for the victims have described the arrangement as a sweetheart deal the well-connected Epstein and his high-powered legal team achieved by putting pressure on prosecutors. Epstein served 13 months of an 18-month sentence on the two state charges before being released in 2009. He's now a registered sex offender. The new court filing, submitted by Florida lawyer Brad Edwards and former federal judge Paul Cassell in a federal court in West Palm Beach, Fla., asked that Jane Doe #3 and another woman be allowed to join the pending case over the victims' rights claim. "Epstein...trafficked Jane Doe #3 for sexual purposes to many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3 to describe EXHIBIT R the events that she had with these men so that he could potentially blackmail them," the court filing said. "One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein's and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin Islands," the legal pleading added. Dershowitz called the allegations "totally made up and totally fabricated from beginning to end." He said he was not in the places described in the filing at the relevant times, with one exception: he did visit Epstein's private island in the Caribbean on one occasion. "I was there with my family," the renowned law professor said. Dershowitz said in a follow-up interview after this post first appeared Wednesday that he's planning to file bar complaints against Edwards and Cassell for inadequately vetting their client's story. "I'm planning to file disbarment charges against the two lawyers who signed this petition without even checking the manifests of airplanes or travel itineraries, et cetera," he said. "I'm also challenging the young woman and the lawyers to level those charges against me outside of the courtroom, so that I can sue them for defamation.....Finally, I'm challenging the woman to file criminal charges against me because the filing of false criminal charges is a crime." The motion accuses Prince Andrew of similar actions, asserting that "Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls)." Previous press accounts have reported on Prince Andrew's friendship with Epstein, who was known as a philanthropist and supporter of scientific research before the criminal investigations began nearly a decade ago. However, the earlier accounts stopped short of accusing the prince of sexual involvement with girls Epstein procured. In a 2011 Vanity Fair story, Prince Andrew denied any such contact. While a Buckingham Palace spokesman did not respond to POLITICO's query about the matter on Wednesday, the palace issued a denial to several British news outlets Friday. "This relates to long-standing and ongoing civil proceedings in the United States, to which The Duke of York is not a party. As such we would not comment on the detail. However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue," the statement said. Prosecutors said in a 2007 draft letter they'd identified 40 young women who could be considered victims of Epstein's illegal acts. Many of them filed lawsuits or claims against Epstein and reached out-of-court settlements for amounts that were not disclosed. EXHIBIT R While "Jane Doe #3" is unidentified in this week's court filing, her story appears to track with that of a woman who sued Epstein in 2009 and settled with him later that year. She apparently granted an on-the-record interview to Britain's DailN Mail in 2011. Some of the fascination with Epstein on the part of tabloids and glossy magazines stems from his ties to former President Bill Clinton. In 2002, Epstein provided his 727 to Clinton for a trip to Africa to study anti-AIDS programs. Celebrities such as Chris Tucker and Kevin Spacey came along for the ride. The new court filing makes no mention of Clinton, Tucker or Spacey. The federal investigation obtained manifests for Epstein's private jet travel, but prosecutors never charged anyone besides the investor with involvement in obtaining or using underaged girls for sexual purposes. The new court filing says this result is in part due to the fact that Epstein's legal team—which included such heavyweights as former independent counsel and solicitor general Ken Starr, trial lawyer Roy Black, and Dershowitz—negotiated a deal that precluded the feds charging anyone as a co-conspirator. Lawyers for Jane Doe #3 argue in the new motion that Dershowitz put this language in the agreement to protect himself. However, the law professor told POLITICO he didn't negotiate that deal and it wasn't aimed at protecting him. "I had nothing to do with drafting the non-prosecution agreement," he said. Dershowitz added that the last draft of the agreement mentioned four people by name who wouldn't be prosecuted and he was not among them. All were regular associates or assistants of Epstein, the lawyer said, adding that the final language removed those names and simply barred federal prosecutors in South Florida from going after any potential co-conspirators. Epstein and his lawyers fought hard to prevent records about his plea negotiations from being turned over to victims' attorneys. However, U.S. District Court Judge Keith Marra ruled last year that the victims are entitled to examine those records to prepare their case against the government. Epstein, Black and others appealed that decision to the Atlanta-based 11th Circuit Court of Appeals, but it ruled in April of this year that no privilege protects plea negotiations in this sort of dispute. Edwards and Cassell did not respond to requests for comment for this post, including an inquiry about their response to Dershowitz's comments. However, the pair appear to be pressing forward with the victims' rights lawsuit, which seeks to unravel the no-federal-prosecution deal cut for Epstein in 2007. UPDATE (Wednesday, 7:18 P.M.): This post has been updated with further comment from Dershowitz. EXHIBIT R -------- Original message--------From: Abi Schwinck Date: 16/01/2015 05:16 (GMT+07:00) To: Pink ,Jean Luc Brunel „Jeff Fuller Subject: FW: Victoria From: Erik Bechtal [m ai Ito : erik@pageparkes.corn1 Sent: Thursday, January 15, 2015 5:12 PM To: Abi Schwinck Subject: Victoria Hey Abi1 Hope you're well. : ) I've just had a conversation with Victoria, and she isn't comfortable remaining with MC2 with all the drama going on right now in the press. She's asked me to contact you on her behalf. Please let me know if you see any issue with this. Thanks so much! Erik Bechtol Agency Director Page Parkes Houston v‘, w.patleparkesage ncy.com The Page Parkes Building 1535 West Loop South, Suite 110 EXHIBIT S Houston, TX 77027 P: 713 807.8222 F: 713 807 0055 EXHIBIT S