Jean-Luc Brunel subpoena

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST THOMAS AND ST JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Plaintiff CASE NO ST 2020-CV 00014 v ACTION FOR DAMAGES DARREN K INDYKE in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST RICHARD D KAHN in his capacity as THE EXECUTOR FOR THE JURY TRIAL DEMANDED ESTATE OF JEFFREY E EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST ESTATE OF JEFFREY E EPSTEIN THE 1953 TRUST PLAN D LLC GREAT ST JIM LLC NAUTILUS INC HYPERION AIR LLC POPLAR INC SOUTHERN TRUST COMPANY INC JOHN AND JANE DOES Defendants PLAINTIFF S SUBPOENA TO THIRD PARTY JEAN LUC BRUNEL In accordance with Rule 45 of the Virgin Islands Rules of Civil Procedure and pursuant to subpoena issued in the pending action Government of the United States Virgin Islands \ Estate of Jeflrey E Epstem ct 01 ST 20 CV 014 before the Superior Court of the Virgin Islands Division of St Thomas and St John, you, Jean Luc Brunel, are hereby commanded to produce and deliver all documents responsive to the Requests set forth below to Carol Thomas Jacobs Esq within 30 days following receipt of this subpoena If you have any questions please contact Carol Thomas Jacobs Esq INSTRUCTIONS 1 When providing Your responses indicate the Request to which each Document or answer responds in the metadata field Request No 2 Documents produced pursuant to these Requests shall be produced as they are kept in the ordinary course of business 3 For each Document that You produce produce the current version together with all earlier editions or p1 edecessor Documents during the relevant time period, even though the title of earlier Documents may differ from current velsions F01mat fox Documents produced electionically a Data shall be p: oduced in single page TIFFs at a 300 DPI resolution which are named for the Bates Number of the page There shall be no more than 1000 images per folder Bates numbers, confidentiality designations, and redactions shall be burned into the TIFF image file so as not to unreasonably obstruct any information on the page b Document Unitization Each page of a Document shall be electronically converted into an image as described above If a Document is more than one page, the unitization of the Document and any attachments and/or affixed notes shall be maintained as it existed in the original when creating the image file and appropriately designated in the load files The corresponding parent/attachment relationships to the extent possible shall be provided in the load files furnished with each production 0 Include Document level text files containing optical character recognition ( OCR’ ) or extracted text named with the Bates Number of the first page of the Document 2 d Include data load files containing all of the metadata fields (both system and application see list below) from the original Native Documents e Include the database field name in the first line of the metadata file in such a manner that it is clear how the metadata is organized in the file f All hidden text (c g track changes hidden columns comments notes, etc ) shall be expanded, extracted and rendered in the TIFF file g Documents created in Excel (spreadsheets) CSV files, Access (databases) and audio and video media files shall be ploduced in Native format The extractable metadata and text shall be produced in the same manner as other Documents that originated in electronic form (as described heiein) to the extent that metadata exists or is reasonably accessible h Email attachments and embedded files 01 links shall be mapped to their parent i Produce all attachments to responsive Documents attached to the responsive Documents j De duplicate prior to production To the extent that exact duplicate Documents (based on MDS or SHA l hash values at the Document level) reside within a party’s data set each party is only required to produce a single copy of a responsive Document so long as there is a data field that identifies each custodian who had a copy In addition Documents may be de duplicated in such a way as to eliminate earlier or incomplete chains of emails and produce only the most complete iteration of an email chain so long as there is a data field that identifies each custodian who had a copy 3 REQUIRED METADATA FIELDS 4 4 —— Format f0: hald copies of Documents produced in iesponse to this Request a Re type the question 01 tequest to which the Documents respond and firmly attach the Documents to the re typed request; b Number all Documents consecutively consistently with the numbers used for the Documents produced electronically 5 Unless otherwise indicated, the relevant time period for this Request for Production of Documents is January 1, 1998 to the present 6 If no Documents responsive to a particular request exist, so state 7 As to any Document which no longer exists but which You are aware existed at one time identify such Document with as much particularity as possible and in addition identify the last known location of the Document the reason the Document is no longer in existence and the person responsible for the Document 5 disposition 8 For information that You withhold on the basis of privilege, provide a descriptive list of each Document stating the grounds for Your refusal and providing the following 5 information the name or title of the Document; a description of the nature and subject matter of the Document sufficient to enable a meaningful challenge to the assertion of privilege the date author(s) sender(s) and recipient(s) of the Document including whether the person is an attorney and/or was an employee of First Bank at the time the Document was authored sent or received and the nature of the privilege 9 These requests shall be deemed continuing in character so as to require prompt supplemental tesponses if additional Documents called fot herein are obtained discoveled or become known to You between the time of responding to the Requests and the final disposition of this action 10 Social Seculity numbers may be redacted from documents to the extent required by applicable law DEFINITIONS Unless otherwise specified, the documents specified below are requiled to be produced for the time period commencing January 1 1998 and continuing through the present Where production of account data is provided in electronic format or media the preferred software fomat to incorporate the data into is Microsoft Excel As used herein the following terms are defined as indicated 1 "All/Each " The term "all" and "each" shall be construed as all and each 2 "And/Or" The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope 3 "Communication" means the transmittal of information (in the form of facts ideas inquiries or otherwise) 6 4 The terms ”Document" or "Documents” are defined to be synonymous and equal in scope to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, without limitation any written drawn printed, typed photographed or other graphic or electronically or computerized recorded data or compilations ofany kind or nature prepared or received by or in the possession custody or control of the answering party its agents servants employees or other representatives Originals drafts and all non identical copies are separate documents within the meaning of this term 5 The term "identify" when used with leference to a person means to give to the extent known, the peison's full name, present 01 last known address, and when leferring to a natural person, additionally the present or last known place of employment Once a person has been identified in accordance with this subparagraph only the name of that person need to be listed in response to subsequent discovery requesting the identification of that person 6 The term "identify" when used with reference to documents, means to give to the extent known, the (i) type of document; (ii) general subject matter; (iii) date of the document; and (iv) author(s), addressee(s) and recipient(s) 7 The term "identify" when used with reference to an oral communication, discussion, conversation or any other oral statement, shall mean to describe in detail the substance of each such communication discussion conversation or statement state the date of such communication discussion conversation or statement the place where such communication discussion conversation or statement was held and identify each person present for such communication discussion, conversation or statement 8 "Referring to" "relating to" "reflecting" "regarding" or "with respect to" mean, without limitation the concepts pertain to deal with concern reflect, record report constitute contain mention describe discuss analyze evaluate estimate study survey, project, 7 assess, support, modify, contradict criticize, summarize, comment, or otherwise involve, in whole or in part 9 You” and ‘Your” shall mean Jean Luc Brunel These terms also shall be deemed to include all agents and other persons acting or authorized to act on his behalf 10 Employee” includes but is not limited to, all current or former salaried employees hourly employees independent contractors, and individuals performing work as temporary employees for the entity refened to in the request 11 ‘ Agent” refers to any individual 01 entity auth01ized, 01 appalently authorized to act on behalfofJeffrey Epstein, including but not limited to Darlen lndyke Richard Kahn,- -———andmr￾12 Epstein Entities ’ shall include but not be limited to, Jeffrey E Epstein; Estate of Jeffrey E Epstein' The 1953 Trust JEGE LLC' Cypress Inc Financial Ballistics LLC FSF LLC FT Real Estate Inc Great St Jim LLC' Hyperion Air LLC 100 Company LLC Jeepers, Inc Laurel, Inc ; Little St Jim, LLC; LSJE LLC' LSJ Emergency, LLC, Maple Inc Michelle’s Transportation Company, L L C ; Nautilus, Inc; Plan D LLC Poplar, Inc Prytanee, LLC, Southern Country International, Ltd , Southern Trust Company, Inc Southern Trust, LLC, Thomas World Air LLC VT&T LLC; Zorro Management, LLC Mort Inc CDE Inc Freedom Air Petroleum LLC C O U Q Foundation Epstein Foundation Inc Epstein Interests Gratitude America LTD J Epstein Foundation Inc Southern Trust Co Financial Trust Co IGY AYH St Thomas Holdings LLC Butterfly Trust LSJ Employees LLC CDE Inc NBS LLC Financial Informatics and Ergo EB 2014 Ltd 8 REQUESTS FOR I RODUCTION Pox the time puiod lanumy l 1998 to plesent REQUEST N0 1 MI} and all Doeuments in demonic 01 papa [01m ILllLLlan 01 telatinn — to an} 1elati0nship bet“ Len YOU _and—— and_ includinU but not limited to any and all financial ananwments and ounuship intuests ammo LdLll REQUEST N0 2 Any and all Documents 01 matuials in demonic 01 papa l01m telleeting 01 lLlLlllng to m) financial tlansattion made to h) 0| bet\\een YOU and lelhe} Epstein and/Ot an} I pstein Avent 01 l pstein l ntity REQUEST NO 3 An} and all Documents C mmmmieations m Matuials telated to an) and all t1a\ Ll to the Viwin Islands 01 01 lm an} female that YOU 01 an) modelinu 01 talent agemy with which YOU wen all'lliated allanged 01 assisted in ananging REQUEST NO 4 An) and all Docmmnts 01 matuials telleeting 01 Ielening to YOUR haul t0 the Vi10in Islands at any time hom 2000 to pustnt REQUEST NO 3 Any and all Connnunieations with lellley lpstein antl/m an) Lpstein Anent 01 Epstein Emit) “hethel it be mitten t.lLLIlOI]lC telephone 01 othemise REQUEST NO 6 An) and all agleements bet“ een 01 among YOU lethe) Epstein and/01 an) I pstein l ntit) 01 l pstein Agent REQUEST NO 7 Documents sutficient to ldentil) an) 1nd all ploperties 01 offices utilized b} YOU 101 the opelation of any business ineluding the adduss of each ploputy 0r OlllLC and the ownet 01 lLSSOl 01 such ploputies 01 ()lllces REQUEST NO 8 An) and all photos and/01 videos of an) plopelt) muted b) Iethe) Epstein and/o1 an} Epstein Emit) in YOUR possession ineluding undex elopLd film and digital images 9 REQUEST NO 9 Any and all photos including digital and still images and/or videos of any females YOU either arranged to traveled to the Virgin Islands or with whom YOU traveled to the Virgin Islands REQUEST NO 10 All Documents Materials or Communications regarding Jeffrey Epstein including, but not limited to, Documents, Materials and Communications regarding females sought by or provided to Jeffrey Epstein REQUEST NO 11 All Documents Materials 0| Communications reflecting any catalog brochuIe, 01 other document reflecting photogiaphs and/or demogiaphic information related to models employed by any and all modeling agencies with which YOU have been affiliated REQUEST NO 12 All Documents, Materials or Communications reflecting or regarding any and all arrangements contracts, agreements, appointment, schedules or other documents or communications related to photo shoots in the Virgin Islands for or with any model associated with YOU or an) modeling 01 talent agency with which YOU were involved REQUEST NO 13 All Documents, Materials or Communications related to YOUR recruitment, or the recruitment by any modeling or talent agency with which YOU have been involved, of any models or talent for any individual or entity, including but not limited to Jeffrey Epstein, any Epstein Entity, or— REQUEST NO 14 Any and all Documents, materials or communications in electronic or paper form reflecting or referring to any financial transaction made to any model or talent agency provided by you or any modeling or talent agency with which YOU have been involved by YOU Jeffrey Epstein and/or any Epstein Agent or Epstein Entity including but not limited to any contracts whether executed or not promissory notes or other financial assurances REQUEST N0 15 A copy of any legal Complaint, newspaper or other media article electronic or otherwise or police report, referring or relating to any complaint of abuse 10 against YOU filed by an) indiVidual includinU any lemalL u11ployed by YOU in any modding 0r laanl agenq \\itl1\\l1icl1 YOU 11am bun im 01x ed REQUEST NO 16 An) and all D0um1u1ls 01 Matuials Muted 10 an} lggal mamas pmsuud against lame) Fpstcin and/on any Epslgin 1 11th) REQUEST NO 17 M1} and all Docun1u1ls Matexials 01 (0111111Lll1ica1i011s Iclated 10 an} Visas 01 il11111i<nalion documents 101 any lunale command l1ilcd 01 L111pl0) d [1) YOU 01 any modding 01 talu1t aguk) \Aith “hiLh YOU “€16 involed including but 1101 limited to an) dOLUanlb ulated 10 lwdl seniccs to obtain Visas 01 001a in1111ig1ati011 dOLLlnlLIIIS and am and all Longspondcnu and L0111111L111iLalions “ith— Rcspultull) SllblfiiIILd DENISI N GEORGE l SQ A RNl Y GENLRAl Dated Novcmbu 4 2020 B) AROL THOMAS W JA S ESQ 0116chqu Attornc) Gt. 1a] Vi1gi11 Islands Depallmml of Iustice Office 01 1h; Attomey GLnual 34 ”)8 Klonplindsens Crack. GERS ( 0111plex 211d How St 111011115 USV100802 (340) 774 3666 Ext - 39 LINDA SINGER ESQ MOTLE\ RICE LLC 40! 91h Sued N“ Sum 1001 “35101101011 DC 20004 Tel (202) 232 3304 Fax (202) 386 9622 lsi112c1/(DI11otlLy1ice (.0111 4110/ m1 f0; P/umufl (Joulnmem of flu ( mch Slum I 11g”) Islands 1 1