on 11 THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA

on 11 THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA O IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY. FLORIDA MUM e4 ays. U DISTRICTS K OTHER PLAINTIFF(' JEAN-LUC BRUNEL CML ACTION SUMMONS (b) Form for Personal Service on a Natural Person VS. DEFENDANT(' JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG CASE NUNN& 14021348CAO CLOCK Rd THE STATE OF FLORIDA:TO EACH SHERIFF OF TIE STATE, YOU ME COMAANDED to See Elm Swain al S Taff/ 0/ lie Cpnpil4 In thla lawsuit on ereloniant: To Delanclanit JEFFREY EPSTEIN I Aisremeuk,-Wrint) ciiee 4-2. * ' 358 El Bab Way On Bead% FL 33480.730-a se-ret 4:t i siti-tratt I VAC BIE21TME A Iowa* hes boon Ned ad eau yes. You has., 20 uWnM1w days Sr this summons la served on rat to Me a wain reedy sa I attsUrd complaint with the dere of Um court A phone CM .40 not pulsar./ Tax written response, ectucling the came number SCAM end nu tomes of the pertly must be Mod if you want Me coal to Nor your Side of the nee. If you do not Me your tint you may lose the case. and your wafts. money arc pr party may Orrearier be taken without further swig from the Coin We Cdhsr Sepal nquimmente You may want to call an enceeey ape away. If you do not know on Storey. you may as an paean set Ore legal ad offal fisted in an %am V004 If you diode to fib a written nreorna rase( at me sn out fie your erten reSCOnScr wdh Me Clerk of Me Cast. r mail a lake a arm of your tendon /spacebar. 'Planter Attorney named holow. The rad& location of dm the Dade Coady Cowthouse. The address for the . act kicatcos are fisted tem for your ra DADS COUNTY COURT LOCAnOtes ®be, Ow* Cass". e61 O.1.amth CM CC (30) Ross ,33 Noma 103 73 MS Fisja seed sem mw a Assn lam,. •W.1, 1213C aria. IWO. 32142 ElYam Wei Oman Can Os) O care caw Ousts Cod psi Res 200 Arm 100 1130 wastimagol A.w.ie 3103 Pees Os Ise NI Masi lack Fiona. Iii Ca0 a RIOS 33134 I11msh Min (21) Room 100 11 Ent 611•Sbeel 1.114•04. Flo," 330111 PlalrelPlairtiff Attorney JOE IfTONE Florita Bar No. 203882 HARVEY RUMN CLEM( OF COURTS O .1mM On Atoka Comm 1/31 Room 100 Isles Room, 131W. Mei Moo newt nonce um 0 Seat Deis Amass Csalm Del Ross Om lona ON 211 SIRS away "Isla IMO SERVICE Addis: 821 M. STH STREET, POMPANO BEACH. FL 33080 VERA snicsitr DEPUTY CLERK fr.ai 0920,7N the Oven d on NOM anal ebo ▪ ai AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order to it olio participate in this proceeding, you are entitled, at no cost 1 o the provision of certain assistance. Please contact the Eleventh Jud al Circuit ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW Ave. Sui e , Miami, FL : 3128, Telephone (305) 349-7175; TDD (305) 349-7174, F (305;349-7355 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711." CUMT 07o leer Wit Iamb eitimat aresidadartran EFTA00599855 O EN LA CORTE DE CIRCUITO DEL UNDECIMO CIRCUITO JUDICIAL EN Y PARA EL CON DADO DE MIAMI-GADE LA FLORIDA o EN EL TRIBUNAL DEL CON DADO EN Y PARA CL CONDADO MLAMI-DADE, LA FLORIDA DIVIMOti 0 MAL l] OMA EMPLAZAM/ENTO DE ACCION CML (b) NOTIFICAC1ON PERSONAL A PERSONA NATURAL DEMANDANTE(S) VS. DEMANDADO(' NUMERO DE CASO HORA Demandado(.: HISBIStrE LAOS ha Wo demandado iromineme. Tin 20 da, cadet* a pak Oei recto de Ms mitecaden. para eenbader la dereanele Wan& Pet aele. ~aria arde oste Mant Uni pateada lelefOnica no b protegera. Si tata diste que el Miami urmden su danse dabde Vaarder Su rtsPuesta Per et‘no. Itackayerrdo el namen del cao y bs nombres do a panee Ireenamdes. SI tated no tonale le dealende banco. tabee parrclet el raso peul rla 501 deepeeedo da sin k9(5505 ypIDpiedid135. 0~0 de spa deredios, tr steno aviso del bemat &eten aree and:secs legt. Wodan. aaide meed consultar e In abapalo inmedatamerde SI ro coma a tm ~do. puilde Wren uns de las eilaas de aatimaaa lepel Dna Nd Office) o un soeks° da referenda de aboaadea (Attomey %terra Servet° que spermen en guia lekNonea. SI daas 111007150f e Ie demanda por su asemt al mismo Liza en qua poesta' su reeuws-ta a* ei tribunal, dera talud enviar pier COMBO o eallregar en la mano ima copla de su raspuesta a la persons dencenineda ab* ome Atlant( Momenten» o Miegel° dei DernandentOyprosenlar w coreetacon ad deinende al Secneado del 'luisde. La utaicson centra' nu la Mina dei Sárodanb este en ei edididede ta Cate dei Genood/. de Da*. La direadon de la Cate. y de las sucursales ~een mat/aa siodente part su comeniencu : LOCAUDAD CE LOS MOUWES DE. COIMADO DE OASE 0 aa alt, ~na 105) D Jota Ca Ca OOI n la Ca AS Cas. (731 eta~ ~te all Roos 133 Roca 103 qat Im Olourn 130 73 Wed nflet Stmol sado MM 71 Aa 15555 eiscaym ene. MEEN) 51)51-ont ~a Modoe 30130 hisore, Pla 3330 M.a Ye. lkoon netd• »OIO man las rini" K asara ~ei orna Cao« (1)) n L. Card am Ca mn Ct5) O sant adde Judas Ca OM ns to» Ra. 100 Ra 1110 1130~ dama 3103 Pal On Le. me MI/10 OS 211 Sa al sem Mondo 0130 Cad Ga ~de 71114 nroln 33.10 Dernandenle oAtopedo Od Demandante DirecciOn: Numero del Cdegio de Abogados: EL ESTADO DE LA FLORIDA: A cada Sad! del Estado: Se le ordena que hagen entrega de esta notifiC3CiOn y u Ma de b deinende en este 511110WdlifiltaldOle flteredOrdell HARVEY RUM Senegal(' del Tribunal del POR: Condado COMODOCeelario Atijunto Ley para Estadounidenses con incapacidades "Si usted es una persona miausválida que necesita hater arreglos para poder parbeipar en este proceso, usted tiene derecho, sin gasto alguno, a que se le provea certa aguda. Por favor póngase en contacto con el Coordinador de ADA en el Onceavo Deitrito Judicial ubicado en el Lawson E. Thomas Courthouse Center, 175 NW lst Ave Sala 2702, Miami Fl 33128, Teléfonos (305)349-7175; TDD (305) 349-7174, Fax (305)349-7355 por lo menos 7 dias antes de la cita filada para su comparecencia en los tribundles; o anmediatamente después de recibir esta notificación si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacilación del &do ode la voz, liame al 711." FECHA CIWCT 070Rer 11111 IffiabeddrecamnitabioNdernalerli.ceni EFTA00599856 0 AU TRIBUNAL DU ONZEME ARRONDISSEMENT JUDICIAFtE DANS ET POUR MIAMI DADE FLORIDE. O AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE MIAM-CADE. FLORIDE DIVISION 0 CMLE 0 AUTRE PLAINTE() A (AUX) ACCUSER) CONVOCARION a ACTION CMLE (b) LIVRAI ON PERSONNELLE A UNE PERSONNE NUMERO DE CAS VS. CONTRE ACCUS3) HEURE IN ADRESSE: IMPORTANT Des poursuites judiciaires ont ete agiotas atm vota. vous avez 20 fours coraucts parer a de ka da de de aile citelion pour deposer nie response ease au plante Sente aspres de ce blutai. Un smile coup de telearee nid Na issant pin vous palet Vous etes Mais de Nia« VOMI, marne ta, nec mena du mana de dosa ch-dessus el du nom des ales manses id, si vous souhaitez que in bibunal entende vote causa Si as ne Mati pas coots repense eat dans le ai roda vous ratez de perdre u taus. ainsi que atm saliens votre nient awl Na puma uts sass par la sa, auzun puma ulleneur du tribunat I y a dautres obligations juridiques et vous pouvez redue& Ws »Mecs intrellas d'un avocat. Si vous n• coma ismii pas de vocal. voue pOumez »Mahomet a un stria MOMMVental (fiants ou a in biseau tram:Sanaa jenkledue (figurai • rarnualre do WephonteS) Si vote Choisissez de decca vousarne ire repense cette a vous faudra radernert, en mena bangs quo cette forma, faim parie nit ou espace« une copie de vote Merda Allonwe (Plaignant ou asat voca s a t) =Mn ci la votre ira avec le Grollim du Tribunal. para du bureau du Greffer a Dade County Coulthixae,Illiteedgu Inn ment des usa:unsles sont dans u dessous pour are osa rua ACIRESSES 1PMINNO( 194 da O DM Corn Caunnom mie O arin Cil. ce MI 1 n Rem lea Noah Ose Sale CAMilur. ROM In Ream34 Haie na nu SoM Rats me cola ni New /3 Win stn. Pa t 544el W4 2/ Menue Rem lee see, see,pow art ISSU Navre fa. mer new' 'bru 231 p t tint ern Sena swere ras »Omo D MM Ne» Otte Cam IN/ D Cal Gaies Ibild Gan CS) Li ses os. Wace Ca (1» Rem 3•3 Mann Mg Rem Inn II» WoMongion Asa Na Poix* or Lm. end Une Zak 111 Sne kW» Ose. noies MI» Cal CS nom WIN hW» Ridas NI» Plainte/Avocat du Plainte Numero de barreau de la Ronde: LTAT OE LA FLORIDE A chaque eherif de roast vote etas oblige de presenter cette citation et une photocpie de la platinas fo ce document sur recouse (e) a-desta Adresse. HARVEY RUVIN Greffier do Tribunal PAR COPIE 13fflefER AMONT DATE ON: ACT DE 1990 POUR AMEWCAINS HANDICAPES AVIS DE r ADA "Si vous êtes une personne handicapée qui a besoin d'accommodement pouvoir participer Iatte procédure, vous avez le droit, sans aucun coût, d'avoir de disposition. al vous plaît contacter le Coordinateur de l'ADA du Tribunal de Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW i n Ave. Suite 2702, Miami, FL 33128, Téléphone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 au moins 7 jours avant la date de comparution au tribunal, nubien immédiatement après avoir reçu cet avis si la date avant la comparution est moins de 7 jours; si vous avez une incapacité pour entendre ou parler, appelez le 711." Œ/4C7.070 Ray 11111 Caca siebeddre« wantemideded•Wee EFTA00599857 MN TRIBUNAL ONZTEM AVVONDISMAN JIDISYE MAN E POU PAIAPSDADC COUNI Y. FLORIDA 0 MAN TRIENNAL E POU TRIBINAL IMAN MUUSDADE COUNTY. FLORIDA. DIVIZTON U SML 0 LOT PLENTIFII) KONVOKASYON POU KA SML (b) DEUVRE PERSONELAIAN BAY VON NIOUN VS. KONT MUA) NIMEWO nA ADRES: Eagarl LE Yo entre yon aksyon kont oumeum. Ou genyen 20 jou kalandnye aptes ou recevoi sornasyon-an pou enregistre b evan greRe tribunal-n. yon renonce pa cal attache avec plenta. Yen apel Pa Melon ka kapab grolege-ou. Se yen repense pa ecritio ou ma mimero ka-a lei sou tel pagaie avec yo lei sou papie-sa oblige esi si ou vle ke tribunal-la Ande position-ou coujoa6SI pa enregistre neponos-ou a ou capab pedu ka-a sen tribunal la pa OnCRITtC01-012 ed yen. ou capab pedu IM ou ale byen ou. Genyen lot demande. Ou ka besoin telefone yon avoka tout de suit. Si ou pa lonen yon avala. ou ka rele sein kl rekernsede avoka, ou dro edu regel (lu flan lis liv nierons). Si ou Moisi voye yon renoncer pa mai oumanm. ou supose on mem tan poste en mem tan poste on pote on Copi retapons. pa eut pou avoka pleyan ou pleyan-yo ke norNi ama-a et enregistre repooœ-la nan tribunal-la kl Ricane nan svek Sbkrete Tribinal. Admis amiral biwo Secrets a se Dade County Courthouse. Adres bibiruil la, ale adres lot tribinal yo nan lis lei 1 nba a pou ou ka jamn yo aber ADRES MIMAI- HAN DAM COURT' n m. Caser Caraimi• fte1) 0 Joue Cale Canar (NO 0 Mat DM Jais Came CM Ro= 133 Rte 103 Rom 100 73 Wall Rader Strie Se MW 22 Mitron 1$563 PernreBntl 111a fana 1f1! 11mM, Rama 33142 ara MM OMM. Rate 33160 13 Mise lise Mima Coda MM 0 Cati 0•11« Oint Cota MS/ 0 Soue OIS AMY» Cela pel Rem 200 itse 100 flœm 1200 1130 aailwiton Moruo 3100 lems ne WI aM M710 Da 211 Star Mea IMIIM rl.a MI 30 fiml 0SS Hama 33134 10001*. Patate 101a1 LI 1001•M Olottla f2t) Room 100 II Fe« 610 Mme MONO. noble 330,0 Railla/Avocat du Plainte Numerus de barreau do la Ftride: ETA FLORIDA: Pou Chak nan eta s yo odane ou peu bey akta e (yo), nan I dot 81111.0 a. manda na* yon Ø yo pote nase sa il. Mme nain noka a. Address: flat HARVEY RUVIN Selerata .leneral TrIblml La BAY: SEKRETE DATE: LWA 1990 POU AMERIKEN KI ENFIM AIMONS POU AMERIKEN ICI ENFIM "Si ou se yon moun Id enfin' e ou benwen akomodasyon pou ou patisipe nan pwosedi sa a, ou gen dwa pou yo ba ou kèk &I sari ou pa gen pou ou peye. Silvouplè kontakte Kowôdinatè ADA pou Tribinal Onzyèm Distrik Jidisyè a nan: Lawson E. Thomas Courthouse Cent«, 175 14W le Ave., Suite 2702, Miami, FI 33128, Telefan (305) 349- 7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan ou gen randevou pou ou paret nan tribunal la, oubyen imedyatman M ou resevwa notiftkasyon sa a si o s gen mwens ke 7 jou pou ou paret nan tribunal la; si ou gen difilcilte pou ou tende oubyen pale, rele 711." altrat. 070 Mer 11n1 met RØ se« rruneelaasteSenen EFTA00599858 Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL. individually. and MC2 MODEL & TALENT MIAMI. LLC Civil Action No.: 14-21348 CA 01 Plaintiffs. vs. JEFFREY EPSTETN. TYLER MCDONALD. TYLER MCDONALD D/B/A/ YLORG Defendants. AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND DAMAGES COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami. LLC, by and through undersigned counsel, and sues Defendants Jeffrey Epstein. Tyler McDonald. and Tyler McDonald d/b/a/ Yi.Org for legal relief. equitable relief and defamation, and states as follows: I. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County. Plaintiff Jean-Luc Brunel resides in Dade County. Florida. and Plaintiff MC2 Model & Talent Miami. LLC, has an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. 2. Florida Statute 48.193(1)(a)(I) ("long-arm") authorizes service on both out-of-state Defendants (Tyler McDonald. and Tyler McDonald d/b/a/ Yi.Org). EFTA00599859 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jean-Luc Brunel is the owner of Plaintiff modeling agency known as "MC2 Model & Talent Miami" ("MC2"). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 5. Defendant Jeffrey Epstein ("Epstein") is a hedge-fund manager with a residence in Palm Beach County, Florida. Defendant has been the subject of significant media coverage due to charges brought against him involving sexual contact with minors. (Composite Exhibit A attached). 6. Plaintiff Brunel and Epstein have known one another since the inception of Plaintiff MC2. 7. Plaintiff Brunel operated his modeling agency, Plaintiff MC2, without incident until Epstein was first charged in Palm Beach County with unlawful sexual contact with a minor in 2006. He was convicted of soliciting prostitution from a minor and sentenced to eighteen months in prison, of which he served thirteen months. He remains a registered sex offender in Florida as of this day. 8. First, after the initial criminal charges against Epstein were filed in Palm Beach County. Plaintiffs were widely implicated in the media as being "linked" to Epstein. These false stories caused both Plaintiffs a tremendous loss of business. 9. Plaintiffs lost multiple contacts and business in the modeling business as a direct result of Epstein's illegal actions. For example, several photographers will not work with MC2 due to the 2 EFTA00599860 adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking Plaintiffs with those activities: namely, sex trafficking. (Composite Exhibit A). 10. One example of such a photographer was Michael Avedon, who worked with MC2 on photo shoots. Avedon stopped answering Plaintiffs' emails and phone calls after having known Plaintiff for some time. Upon meeting Avedon out one night. Avedon stated to Plaintiff Brunel he had "found out some information" from some friends of his and that he could not associate his name with MC2. II. This statement by Avedon was no doubt a reference to the alleged and false links between Plaintiffs and Epstein's illegal activities with under-aged girls. This incident clearly illustrates an example of lost business on Plaintiffs' behalf. 12. The second example of a business relationship that was terminated due to Epstein's intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos Model Agency. The owner stated that the model to be placed with MC2 "found some article in internet. which changed her position and she preferred to be placed with another agency." This was relayed to Plaintiff Brunel by e-mail dated October 15.2014. This amply demonstrates that Epstein's intentional & illegal activities continue to cost Plaintiffs' business income. (Exhibit B attached). 13. A third example of a lost business relationship can be found in an e-mail dated October 17, 2014 (Exhibit C attached). The director of the I Mother Agency, Vladmir Yudashkin, states that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs- will force her into illegal activities. The model bases her fears upon the stories on the intemet falsely implicating Plaintiffs as being involved with illegal activities with young models. This is 3 EFTA00599861 another example of a false link between Epstein and Plaintiffs, costing Plaintiffs' business income. 14. A fourth example of a lost business relationship can be found in a second e-mail dated October 17, 2014 (Exhibit D attached). Manuela Martinez of Mega Partners, a Brazilian modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs . This reference is clearly to the false allegations online regarding sex trafficking that were based in the false link between Epstein and Plaintiffs. 15. A fifth example of a lost business relationship can be found in an e-mail dated on behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of Epstein's illegal activities. Plaintiff Brunel was forced to forego (and lose) this business opportunity because he needed to keep a low-profile at this time. 16. A sixth example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail dated December 12. 2014. (Exhibit F attached). Michael Sanka, a talent scout who had worked with Plaintiffs for a number of years, informed Plaintiff Brunel that he cannot sign any new models for Plaintiff Brunel's MC2 agency due to the false sex trafficking allegations online. Sanka goes on to state that Plaintiff Brunel's MC2 agency will not attract any new models if Plaintiff Brunel does not clear up the false allegations. 17. A seventh example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail from Fox Fashion Agency (Exhibit G attached). This e-mail clearly states 4 EFTA00599862 that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems. However, because of the false internet trafficking links between Plaintiffs and Epstein, Fox states that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up. 18. Before the false links between Plaintiff and Epstein surfaced. Plaintiff Brunel was earning a great deal of revenue from MC2 Miami. 19. The false links between Plaintiffs and Epstein began to surface online in about 2005- 2006. Then, in 2006. Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs then made an investment totaling one-million dollars with Elite Paris. to start a company. 20. Next, Plaintiff Brunel started the company, "E Management". to work with Elite Models in Paris, Plaintiff had to close it almost immediately, because Elite didn't send any models to Plaintiff MC2 for fear of being linked to Epstein. 2I . Because the false links between Plaintiffs and Epstein began to gain strength online. Elite Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment of one-million dollars because of this loss of business. 22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar loss. 23. Additionally, a former financial controller of MC2. stated in a 2012 deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under- age model. (Exhibits HI & H2 -Transcript of Deposition of 24. was fired from her job at Plaintiff MC2 for embezzling company funds. and had criminal charges filed against her (Composite Exhibit I attached). She was also the source of the false information linking Plaintiffs to sex trafficking in the articles written by of the website Jezebel (Composite Exhibit A. p.2-7). 5 EFTA00599863 25. The deposition testimony of referred to above clearly demonstrates that Plaintiff Brunel has clean hands and was never involved in sex trafficking. All of Plaintiffs' damages came solely from Epstein's conduct. 26. Additionally. Plaintiff Brunel has had significant delays in obtaining his visa to come to the ■. These delays were also the result of the false link between Plaintiffs and Epstein. As a result of these delays. Plaintiffs lost a considerable amount of time & money. International travel is a significant component of Plaintiff Brunel's MC2 modeling business. Plaintiff Brunel has been forced to cancel his latest visa application as a result of the delays. (Exhibit J — Composite — Visa Docs). 27. As a result of the notoriety and tremendous publicity surrounding Epstein's criminal charges. and the media linkage of Epstein to Plaintiffs regarding illegal activities. Plaintiffs lost a tremendous amount of business and revenue. 28. Plaintiff Brunel's agency MC2 has lost millions of dollars in revenue since the media revealed that Plaintiffs and Epstein were associated. In fact. Plaintiff MC2 was worth millions of dollars; now, due to the illegal actions of Epstein. MC2 is almost worthless. 29. At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the Epstein's illegal activities. 30. As a result of Epstein's illegal activities and his association with Plaintiffs, Plaintiffs continue to lose money and suffer damages to this day. (Exhibit K attached. Jeff Fuller email, 11-12-14). 31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to what it was once worth — money that the Plaintiff Brunel does not have. 6 EFTA00599864 32. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names never having been cleared from the massive and totally negative media coverage involving Epstein and his illegal activities. Plaintiffs have been, and continue to be. irreparably harmed by these false internet-based links to Epstein. (Exhibits R &' attached). 33. Second. Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Brunel's deposition. 34. As a direct result of Plaintiff Brunel's travels, his deposition was delayed twice. When it was finally scheduled for November 2009. Plaintiff Brunel was in fact available (Exhibit I attached). However, a medical emergency in the family of his attorney further delayed this deposition (Exhibit M attached). It was never rescheduled and he was never deposed. 35. This was a blatant example of obstruction of justice in the criminal case. Epstein was solely responsible for telling Plaintiff Brunel to leave the area. Plaintiff Brunel lost a huge opportunity to clear his name, and that of his agency. Plaintiff MC2. 36. Third. as a result of all of the facts stated above. Plaintiff Brunel was under tremendous psychological pressure throughout this period of time. 37. This psychological pressure resulted in Plaintiff Brunel avoiding business contacts as set forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts during this period of time. 38. Plaintiff Brunel became extremely withdrawn and anxious at this time. 39. Epstein's conduct was the direct cause of Plaintiff Brunel's psychological state. The press was reporting extensively on the lurid details of Epstein's illegal activities with the under- aged girls. 7 EFTA00599865 40. As stated above. the press reports were erroneously connecting both Plaintiffs to Epstein's illegal activities. (Composite Exhibit A attached). 41. Epstein's illegal activities were outrageous and extreme; they involved receiving massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the girls with a finger or object; or full-intercourse. 42. These activities described above caused Plaintiff Brunel severe emotional distress. In fact, Plaintiff Brunel has recently undergone with a local psychologist, Dr. Royce N. Jalazo. as a result of Epstein's actions and the negative results on his business. (Exhibits N & O attached). 43. Plaintiff Brunel is emotionally destroyed as a result of Epstein's actions and the resultant effects on his business. He has been on medications to deal with the effects of this. (Composite Exhibit P — Medical History). 44. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counsel to represent him in this matter. and are obligated to pay counsel a reasonable fee for his services. FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A YLORG 45. Defendant Tyler McDonald ("McDonald") is the owner/operator of Yi.Org and also does business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org"). Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service based in Vancouver, British Columbia, Canada. 46. In about 2009, Yi.org, by and through the actions of its owner, McDonald. began hosting websites that contained hyperlinks that contained blatantly false and extremely disparaging information about Plaintiffs. (Exhibit Q attached - hyperlink screenshot). 8 EFTA00599866 47. These links clearly and falsely associated Plaintiffs with illicit escort services in the state of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or should have known, was false. 48. These links have damaged Plaintiff reputation as an owner of a well-established modeling agency with offices in New York and Miami, Plaintiff MC2. 49. These links have also damaged the reputation of both Plaintiffs. 50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss of revenue to Plaintiff MC2, and accordingly. to Plaintiff Brunel. 51. Plaintiff MC2 revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Plaintiffs' reputation and directly caused damages to Plaintiffs. 53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day. both names still harmed by the false and negative association with escort services in Florida. 54. Accordingly, Plaintiffs have been severely damaged by information on websites hosted by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 55. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged involvement with escort services in the stale of Florida. 56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the names of Plaintiffs with regard to the false and defamatory information disseminated by the 9 EFTA00599867 websitcs they hosted. 57. Plaintiffs continue to do business to this day, their names never having been cleared from the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald. 58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and McDonald, and have accordingly retained undersigned counsel to represent him in this matter. and arc obligated to pay counsel a reasonable fee for his services. COUNT I — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANT JEFFREY EPSTEIN 59. The allegations contained in paragraphs I through 44 above are re-alleged and incorporated herein by reference. 60. Plaintiffs have lost a significant amount of business revenue because of the actions of Defendant Epstein set forth above. 61. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of Defendant Epstein. 62. Accordingly, Plaintiffs seeks to become whole by the payment of damages by Defendant Epstein to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars: trial by jury and B. Grant other such relief as is appropriate. COUNT II — OBSTRUCTION OF JUSTICE - EQUITY - AS TO DEFENDANT JEFFREY EPSTEIN 63. The allegations contained in paragraphs I through 44 above are re-alleged and incorporated herein by reference. 10 EFTA00599868 64. Plaintiff was forced to commit illegal acts by traveling away from the sight of the deposition and during the time period of the deposition. 65. Defendant Epstein attempted to subvert justice and this attempt contributed to the destruction of business, Plaintiff MC2. Plaintiff Brunel lost substantial time away from his business and incurred expenses in following Epstein's commands. 66. Plaintiffs were substantially damaged as a direct result of Epstein's actions. WHEREFORE. PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT III — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 67. The allegations contained in paragraphs I through 44 above are re-alleged and incorporated herein by reference. 68. Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by engaging in illegal conduct with under-aged girls, which was falsely linked to Plaintiffs. 69. This illegal conduct was extreme and outrageous by any standard. 70. This extreme and outrageous conduct was the direct cause of extreme emotional distress in Plaintiff Brunel. WHEREFORE, PLAINTIFF BRUNEL requests judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate II EFTA00599869 COUNT IV - EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDQNALD Dift/A,YLORG 71. The allegations contained in paragraphs I through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 72. Plaintiff, through his agency MC2, has lost a significant amount of business revenue because of the actions of Defendants McDonald d/b/a Yi.Org and McDonald set forth above. 73. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of both Defendants. 74. Accordingly, Plaintiffs seek to become whole by the payment of damages by both Defendants to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT V — DEFAMATION AGAINST PLAINTIFFS - AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG 75. The allegations contained in paragraphs I through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 76. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published, false statements about Plaintiffs using their domain hosting service. 77. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the statements about Plaintiffs were false. 78. These published statements were read by the Internet users who viewed the false statements. 79. Plaintiffs' business reputations were severely damaged as a result. 12 EFTA00599870 WHEREFORE. PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT VI — EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A/ YI.ORG 80. The allegations contained in paragraphs I through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 81. Plaintiffs have also suffered a significant loss of their business reputations as a direct result of the actions of Defendants McDonald d/b/a Yi.Org and McDonald. 82. Plaintiffs have no adequate legal remedy to make them whole as a result of the damages suffered in the form of lost business reputations due to the actions of both Defendants. 83. Accordingly, Plaintiffs seeks to restore their business reputations by the payment of damages by both Defendants to compensate them for their loss of reputations. WHEREFORE. PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. /s/ Joe Titone Joc Titone Attorney FL BAR #: 203882 621 51h Street Pompano Beach. Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) Joetitone708ecomcast.net 13 EFTA00599871 VERIFICATION STATE OF FLORIDA COI JNTY OF/C2.4.4eI e/he ) JEAN-LLIC BRUNEL. being duly sworn according to law. upon his oath, deposes and says: I have mad the fore-going complaint and all the allegations contained ther/in All such allegations um true based upon my personal knowledge, infurtnutioy and belief. i Sworn and albscribed to before me this / day ofe,,,,e,a-r- , 2014. 1 — ... -- VMLAbWJ Nay St -Pilo el MX Or kes• Sim 0c/ 31. 2016 Calm 0 It 2901. !oriel limp NSW Mean** NOTARY DBLIC 6 14 EFTA00599872 COMPOSITE EXHIBIT A 15 EFTA00599873 http://www.thedailybeast.com/articles/2010/07/29/jeffrey-epstein-feds-probe-possible-child- trafficking-charge.html Epstein Faces Sex-Traffic Probe The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last week. But it appears his problems may not be over. Now The Daily Beast has learned that: • Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge than the two in his non- prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. • The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein's private jets. Because Epstein's predatory habits stretch back many years and involved dozens of young- looking girls. there may well be more evidence to uncover. Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash settlements in these civil suits agreed not to testify against him or speak publicly about the case. However, new evidence developed by the Department ofJustice on other offenses not covered by the agreement, including allegations by additional victims who come forward, could lead to new charges. There is no statute of limitations in the federal sex- trafficking law, which was also enacted by the state of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of young-looking girls. there may well be more evidence to uncover. (Several young women who claim to be Epstein victims have recently contacted a Ft. Lauderdale lawyer. but to date no new civil complaints have been filed.) • The Billionaire Pedphile's Sex Den • Billionaire Pedophile Goes Free These new developments come one week after the publication of two articles in The Daily Beast about Epstein's pattern of sexual contact with underage girls. which Palm Beach police began investigating in 2005 and the U.S. Attorney's office then settled in a 2007 plea deal. The first 16 EFTA00599874 article quoted a deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein. a billionaire with many powerful friends. had received special treatment in both his plea deal and the terms of his incarceration. Although federal investigators at one point produced a draft 53-page indictment against Epstein. he was eventually allowed to plead guilty to only two relatively minor state charges and receive a short term of incarceration: 13 months in the county jail. during which he went to the office every day, and one year of community control, during which he traveled frequently to New York and his private island in the Virgin Islands. The Daily Beast has now discovered another instance in which Epstein apparently received special consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This is because child molesters tend to be repeat offenders with high rates of recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been disconnected with no forwarding information. The Daily Beast's second article provided details about Epstein's systematic abuse of underage girls at his Palm Beach mansion. where members of his staff allegedly recruited and paid a parade of teenagers. most of them 16 or younger, to perform daily massages that devolved into masturbation, groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between Epstein and Jean Luc Brunel, a frequent visitor to whom he gave SI million around the same time that Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas—often from Eastern Europe and South America—are known to have been passengers on Epstein's private jets. The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger. says he has no knowledge of an ongoing probe, and he told The Daily Beast. "Jeffrey Epstein has fully complied with all state and federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his non-prosecution agreement with the federal government." C'onchita Sarnabr has developed multimedia communication programs for Fortune 500 companies and has produced three current-events debate Tit programs. The Americas Forum. From Beirut to Kabul. and a segment for The Oppenheimer Report . She is writing a book about child trafficking in America I7 EFTA00599875 http://www.thedailvbeast.com/articles/2010/07/22/jeffrey-epstein-pedophile-billionaire-and- his-sex-den.html The Billionaire Pedophile's Sex Den Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-dail masse es, pornographic artwork, and hush money—that's only now being revealed. reports on the sordid details in part two of her exclusive expose. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-dail masse es ornographic artwork, and hush money—that's only now being revealed. reports on the sordid details in part two of her exclusive exposé. Also: • Nude images of young girls were scattered around the house and the bathroom soap was shaped like sex organs • Staff trolled for fresh recruits to make sure Epstein had two or three massage appointments each day • The house manager has been sentenced to a longer prison term than Epstein—for trying to sell notes regarding massage appointments • Epstein gave $1 million to his friend Jean Luc Brunel when he was starting the modeling agency MC2 • According to a former bookkeeper, young girls were brought to the U.S. by MC2—often from Eastern Europe—then traveled on Epstein's private jets Jeffrey Epstein's loyal friends say that his prosecution was unduly harsh, rather than outrageously lenient. They insist that his sexual habits, although obsessive and unusual, were mostly legal and essentially harmless. As the police records attest, the girls brought to El Brillo Way were routinely told they could "say no" at any time during a massage as Epstein escalated contact in a step-by-step assault that was remarkably similar in every victim's statement: First she would be asked to remove her shirt, then her pants. Ile would attempt to fondle her buttocks and breasts as he masturbated, then bring out a large vibrator. There was sometimes digital penetration, and the more willing girls were lured into full-blown sexual relations with both Epstein and who was referred to in press accounts and police reports as 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. I8 EFTA00599876 It's true that some underage girls may have lied about their age, and some came to the house voluntarily several times—although, according to Florida statutes, none of that has any bearing on the criminality of the contact, particularly if the girl was 16 or younger. But what is particularly disturbing about this case—judging by arrangements at the Palm Beach house—is that Epstein, a billionaire hedge-fund manager, organized his life around this sexual compulsion in an open and methodical way that suggests he felt he was beyond the law. • Epstein Faces Sex Traffic Probe • Billionaire Pedophile Goes Free According to police who executed a search warrant, the house was decorated with large. framed photos of nude young girls, and similar images were found stashed in an armoire and on the computers seized at the house (although police found only bare cables where other computers had been). Some bathrooms were stocked with soap in the shape of sex organs. and various sex toys, such as a "twin torpedo" vibrator and creams and lubricants available at erotic specialty shops, were stowed near the massage tables set up in several rooms upstairs. E stein also enlisted his staff in the predatory activity, and four . and --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 SI million—an amount that will hardly dent Epstein's $2 billion net worth. The victims told police they waited in the kitchen to be called upstairs for a massage. and the house chef often gave them a bite to eat. House manager Alfredo Rodriguez said in his sworn statement that a maid named Lupita. who was a devout Catholic, wept when she complained to him about cleaning up after the massage sessions, picking up soiled towels and putting away the sex toys. And she was upset that a photo of Epstein with the pope hung next to one of him with a young girl. Ironically. Rodriguez. who ran the house on El Brillo Way in 2004 and 2005, ended up being sentenced to more jail time than his boss as a result of the complex investigation into Epstein's activities. Ile was fired, he says. for inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money. Ile saw an unfamiliar "beater" in the driveway one evening and called 911. When he left Epstcin's employ. Rodriguez took away some notes and emails about massage appointments as "protection" against his own prosecution. and failed to produce them during the Palm Beach Police Department's initial investigation. Unable to get work as a house manager elsewhere in South Florida, he says. Rodriguez later tried to sell this "golden nugget"—his term—for $50,000, to be used in the victims' civil suits. 19 EFTA00599877 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 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 Di trict of Florida, an alleged victim said that Epstein, Maxwell. Brunel, Rodriguez, and "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money." (Which would amount to trafficking.) Brunel is a 50-plus French playboy who was formerly part owner of Karin. a Paris-based modeling agency. He lives in New York and South Beach, Florida. and owns 85 percent of MC2. which has offices in New York, Miami, and Tel Aviv. (The remaining 15 percent is owned by his partner, Jeff Fuller.) Brunel has been observed as a house guest at Epstein's Palm Beach home and may well have had contact with him also in New York, where Epstein owns a lavish home, and in Paris, where Epstein keeps an apartment on elegant Ave. Foch. CBS reporter Craig Pyes, who investigated Brunel for a 60 Minutes broadcast many years ago. is quoted in Michael Gross' book about the modeling industry, Afodel: The l'uly Business of Beautiful Women. Pyes told the author that Brunel "ranks among the sleaziest people in the fashion industry. We're talking about a conveyor belt, not a casting couch. Hundreds of girls were not only harassed but molested." Now The Daily Beast has learned that Epstein had made a $I million wire transfer to Brunel's offshore bank account in September 2004, just as he was setting up MC2. Whether this was a gift or a loan or a backdoor investment in the new venture is unknown. A French citizen who managed to avoid giving evidence in the Epstein investigation, Brunel declined to comment on any of this. as does Fuller. Asked in April of Brunel's activities. 20 EFTA00599878 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 - orieinal report on Epstein. 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 liuffington Post. She is writing a book about child trafficking in America. 21 EFTA00599879 http://fasbioncopious.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- traftickine 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 • and girlfriend Ghislaine] Maxwell, Brunel. [house manager Alfredo] Rodriguez. and 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17. to engage in sexual play for money. 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: b ' bear -old Yugloslavian named from her parents in order to keep 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 EFTA00599880 hnp://bettyfokker.wordpress.com/2.010/08/20/hes-helping-others-get-away-with-child-scx- trafficking/ He's helping others get away with child-sex trafficking Posted on August 20. 2010 by Petty Fokkr Let's discuss that billionaire douche-face child-rapist, JelTrey 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 kiddie-rem-fin 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. 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 filthier 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 EFTA00599881 Ads by Google http://gawker.com/5600294/recentiv -freed-sex-offen der- ieffrev-enstein-mav-face-ch ild- trafficking-thaws Recently-Freed Sex Offender Jeffrey Epstein May Face Child Trafficking Charges !to mt. sita• IMLIMPO. Expand ,leffrev 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 ‘v ith Bill Clinton having an egg-shaped penis. and being a vindictive pervert, can't be for the charges he copped to in his plea deal. But according to the Daily Beast's 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 EFTA00599882 lutp://www.huffingtonpost.corn/2014/06/03/jeffrey-epstein_n_5439407.htm I 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. .lustice 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. filing 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 efTons begun in the 1960s to give crime victims more of a say. 25 EFTA00599883 "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. Seine 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 Man Alexrod. a former federal prosecutor now in private practice in Washington. 26 EFTA00599884 Communications expert Regulating Modeling Agencies to Help Prevent Child Sex Trafficking 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. Bruncl'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 prevent depositions. "Trawling for 5'1 I" 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 EFTA00599885 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 Brunet'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 Jen5me 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 stun "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-traffieked-underage-girls-for-sex The Sex-Trafficking Model Scout 28 EFTA00599886 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 SI00,000 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 inure Which included, for the record: bu in a 4- ear-old Yugloslavian named from her parents in order to keep 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 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 and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez. and 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money.' The FBI investigated Epstein. and identified around 40 underaged victims. Samoff 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 EFTA00599887 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 SI 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, Samoff 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 %isited 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" Lamina via an MC2 scoutint! competition for young teens) and currently represents Vogue China covergirl Liu Dan. Worldwide, MC2 represents such stars as Sessilec 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 "scoutin 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 I 970s 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 EFTA00599888 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 and/or 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" I3-year-olds from Eastern Europe and (the whiter Darts ol) 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? hap://nypost.com/2011/11/ 8/je ffrey-cpste ins-level-3-sex-offender-stat us-upheld-by-ny-appeal- court/ 31 EFTA00599889 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 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 EFTA00599890 http://pagesix.com/2007/10/06/model-shop-denies-epstein-tie/ MODEL SHOP DENIES EPSTEIN TIE By PageSix.com Staff - October 6.2007 I 9:00am TIIE 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, 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 IS. 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 I 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 EFTA00599891 http://www.palmbeachdailynews.cominews/news/lawsuit-documents-link-jeffrey-epstein- to-modeling/nMGO4/ 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 leaned 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 EFTA00599892 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 I8-month state sentence. Ile 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. Clio Af leveral times on Epstein's planes, many times with Maxwell, Palm Beach resident 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 - dresses for Clinton along with 21 phone numbers for him ... and what appears to be 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, Doc 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://slaverroday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-ow-ned- regulation-for-agencies-to-stop-child-sex-trafficking/ 35 EFTA00599893 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 S100. 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 ito 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 Trafficking Trafficked Athletes And now a new one / 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 traffickers: Go to politically or economically unstable areas: locate 5'11"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's family anywhere in the world and offer them this in return for absolute control. All ite 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 EFTA00599894 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. 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 Sarnoff Posted: 02/10/2012 8:49 pm In 2010, Jezebel. an online site. published "The ex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the M. underage teenage m rk Given the growing number of modeling agencies that transport foreign countries into the United States and the growing sex trade of underage girls in the . 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 agencie w York and Paris. According to media reports, Diane Sawyer produced a segment for 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 EFTA00599895 prevent depositions. "Trawling for 5' I I" 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 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 Journalmagazine. In that stun "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 EFTA00599896 http://slastrytoday.org/that-gorgeous-underage-ad-modcl-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-traffickine 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 S100. 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), ! learn about . it knocks me down, one more time. Slaver, Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trafficking Trafficked 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 traffickers: 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'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 :s family anywhere in the world and offer them this in return for absolute control. All ite traffickers have to do is pull out a magazine or phone with videos on it. 39 EFTA00599897 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 itflourishes 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. sheiworking to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conch ita Samoa' Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The S x Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the M. siii Given the growing number of modeling agencies that transport underage teenager m foreign countries into the United States and the growing sex trade of underage girls in the . 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 iii over two decades with a succession of agencie ' w York and Paris. According to media reports, Diane Sawyer produced a segment for 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 EFTA00599898 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' I I" 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 fcc 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 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 Bonnouvricr. "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 Journalmagazine. 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 EFTA00599899 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 EFTA00599900 http://files.walistreetfolly.com/wordpress/2007/10/jeffrey- epstein-doesnt-want-to-be-branded-as-a-sex-offender-for- life-and-no-hes-not-a-modeling-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 Jeffrey Epstein, the billionaire money manager 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 M. 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 — l= 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 EFTA00599901 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 EFTA00599902 http://www.washingtonpost.com/news/volokh-conspiracy/wp/20I 4/04/21/eleventh-ci rcu it-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 I 1th 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. I lere arc the important facts, taken from the 1 1 th opinion: The case arose in 2006, the FBI began investigating allegations that wealth Investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The M. 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 Doc No. I 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 EFTA00599903 On July 7, 2008. Edwards and I filed a petition alleging that Jane Doc No. I 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 w qualified as "crime victims" under the CVRA. The district court later rejected the 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. make the case for such a remedy, we moved for discovery of the correspondence between the M. 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 I I 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 inTeelllelli was a possible remed% 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 ruline, that we could rthie‘A 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.. 86012.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073. 1081-82 (4th Cir. 1981). Even if it 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 EFTA00599904 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) ("[T)he 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 bit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 I. 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 M. 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.. 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 Ass iate Deputy Attorney General with the . Justice Department (1986-88), and an Assistant M. Attorney for the Eastern District of (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 E. District Court Judge for the District of Utah in 2002.1n 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 EFTA00599905 ----- Original message -----From: Jolanta MODILINOS Date: 15/10/2014 4:46 PM (GMT+02:00) To: Jean Luc Brunel Subject: Dear Jean Luc, Flops 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 Jolanta Sadauskiene owner MODILINOS model agency MODILINOS models panyins 7-4, Kaunas Sv. Stepono 7, Vilnius teffax:+37037323257 cell:+37069816103 folantamodilinos com inlomodihnos.com www.modffinos.com EXHIBIT B EFTA00599906 From: *Vladimir Yudashkin Q 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 intemet 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 EFTA00599907 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 MEGA PARTNERS MANUELA W MARTINEZ international Petri= Phone: +66 11 3818.4800 Direct: +65 11 3818.4827 Cell.: +551188668.0080 megentodelbrasilcom.br EXHIBIT D EFTA00599908 Original Message---- From: Lorraine <[email protected]> Organization: MC2 MM Reply-To: <lorraine©mc2mm.com> Date: Friday, August 27, 2010 at 8:49 PM To: <[email protected]>, Jean Luc Brunel <[email protected]>, Pink <pink©mc2mm.com> Subject: FW: Press Inquiry from AFP (Agence France Presse) Videographer--Michelle Stockman >----Original Message >From: Michelle STOCKMAN [mailto:[email protected]] >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 >dlstributed 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 EFTA00599909 >917-533-3261 >www.youtube.com/AFP >Agence France-Presse is the 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 EFTA00599910 Sept 4.0q, Sacrum Yob* ---- Original message -----From. Michael Sanka Date: 12/12J2014 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 tc 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 ycu since they all told me "We know Jean Luc for more than 20 years and ail 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 representea 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 lo 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 EFTA00599911 FOX Ann: Scouting division MC? We took notes of your comments and the girls that you like on our websitc We know Jean Luc Brunel and we always work with him since more than 10 years all those years and nes er had any problems. All the girls he represented from us nes a had any problems. they were working has e 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 met 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 spa 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 38CAC) We are sum but you really need to clarify escry-thing. till then we will base 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 800(410 11000. SwittOOTTA8 35 v SW '2 www.loxmodetcom aniaN: Waffle. tsezempro.yu MI .381 3346414 lig 10 •381 11 3226202 EXHIBIT G EFTA00599912 1 Az 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 Jean-Luc Burnel acted inappropriate with her? 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 the truth. 16 Never. I never heard anybody accusing Mr. Brunel 17 or complaining about Mr. Brunel. Nothing. 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 "something bad happened to me". 22 A Maybe a model came and told me, "Maritza, 23 look what happen to me. I don't have any money," or 24 "I don't have a place to live". Or, "Look, I didn't 25 get my ticket", or whatever. EXHIBIT H-I EFTA00599913 43 1 2 tot. OBRONT: Well, I would object, because 3 of circumstances. 4 BY MR. DAVID: 5 0 But you said before that you never heard 6 anything that would indicate that Jean-Luc Burnel 7 behaved inappr~•priately with -- with any models, q especially any minor models that MC Square may have g 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 0 Right. 6 A And my answer was no. Nobody came to tell 7 me. I never taw. I never knew. His personal life B was ni.t my problem. 9 0 D you have any actual knowledge, that is O to say were you present or did you see with your own j eyes, any minor models go with Joan-Luc Burnet to 2 Jeffrey Eputein's home, CA any party of his? 3 MR. OBRONT: Objection. 4 THE WITNESS: I'm sorry, but I take the 5 Fifth. EXHIBIT H-2 EFTA00599914 COMPOSITE EXHIBIT ! 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Jean Luc Brunei. impressive cumcukrm vitae. verifying his tremendous accomplishments in bath the fashion and modeling industries. EXHIBIT 6 Several cuticles tega•atng the 2004 neratron Contest including translations) as wet as the leading role within Ihr$ prestigious modeling event EXHIBIT 7 Several press LxIxiles regarding the prestigious 2006 Models New Competition lincluding ironer:April os wet as the Jean Luc Brunel. leading role within the event EXHIBIT 8 Letter or Claudia Midcro. President at Madetwork. a renowned modelling agency EXHIBIT 9 Letter or Ala Arnanhava Director cil Figaro IntematiOnal Management EXHIBIT 10 Several Press articles reflect ng the prestige and high circulation tales at the mentioned magazines and periodicals which have featured and covered the modeling events which the betintrary Jean Luc Brunei. hos Organized throughout the yeah EXHIBIT 11 irtormation regarding the extremely successful and prestigious modeling and fashion association International Model Toler). Association (ltiAIA) EFTA00599926 m c2 MODELS MIAMI July 25. 2014 Deportment of Homeland Security Uri'ed Stales Citizenship and immigration Services Vermont Service Center 30 Houghton Street Saint Aloons. VT 05478 RE: 1.129, Petition for o Nonimmigrant Worker O-1 Extraordinary Abiltty as an Art Director and Talent Coordinator PeIntoner: MC2 Models Miami, LLC Beneficiary Jean-Luc Didier Henri-Rene BRUNEL Dear Se / Modem. The present teller and its enclosures ore submitted in support of the attached O-I petition of MC2 Models Miami. 1.1.C, on behalf of Mr. Jean luc Brunel. The petition is based upon Mr. Brunet's standing as on "Alien of Extraordinary Ability in Arl Direction and Talent Coordination " Kindly note that Mr. Brunel currently holds 0-1 status with our ofganizatIon. The South Florida orea and Miami Beach in particular hove become mecca tor the fashion and modeling industries. As a result. many of the fewest international modeling agencies such os 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 foot, Mami Beech hos become second only la New York City in terms of employment opportunities for fashion models in the „flirted States. Attached as EXHIBIT 1 please find several press and media articles documenting the rise of South 9eoch as one of the United States' main fashion capitals. In 1996. our company MC2 (formerly Karin Models!. established on office in the heart of the histonCi lleco District of Wenn Beach. -South Beach' has truly become one of the modeling capitols and we are pleased to tie a pal of it Our agency hos developed a highly distinguished reputation in the modeling .nokistiy We specialize in representing numerous mode:, of international acclaim. Roving discovered faces such as Chnsty Turlington. and rrokied the careers of celetxities such os Sharon Stone. Estella waxen. MAla mrd, man, • 1674 dllon mac; • !kid! 500 • mar , bows(' 33139 305 et? R300 • 'a. 30f. 51? 8330 • a&'m.slrsOnn 309, G r7 7672. • to 305 072 63,4„. mOmm EFTA00599927 Jovovich. Jerry Hall and Rebecca Romp who is currently staffing in the award- winning ABC leleviskon series Ugly Betty, MC2 models are among the most sought otter in the industry. os evidenced by the caliber of thew commercial and editorial bookings. Many of our fashion models hove graced the pages of reading fashion mogaenes of the United States. Euterpe. Latin America. Africa. and Australia such os vogue. Teen vogue. Eøe. W. Glomots. V. Mane Clare. Surface and Cosmopolitan os weft os many more throughout the world. In oddution to our Miami Beech office. MC2 Models hos Offices in New York City and Tel Avrv. As Artistic Director and Talent Coordinator tor MC2 Models Miami. LIC. Mr Brunel well be respiOnlibkt for overseeing the artistic aspects of the agency By overseeing the art department ri the agency. Mr Bruner svir direct the visual marketing al the models to clients. focusing on the images pieced on both the composite cards and thew portfolios Both of these marketing tools are arum' in marketing farina:an models to their appropriate catalog editorial. a media clients. As Melt Director and Talent Coordinator Mr. Brunel wd also ,:oorchnote the paring of fashion models with a particular photographer. Cents for toe agency valuate a Invited of fashion publications. retail starts, consumer product companies. ond loshion houses lo name but a few Recruitment of talented artistic photographers who have on excetlent underltandrig Of the -ins and cede' of the modeling and fashion industry is C4hCal to the successful running of a topmodeling agency such as MO Models will alto continue with he amazing tract record of discovering the greatest talents ond becauhes in order to sign them with MC2 Mader.. Me Brunel we continue to travel around the wale looking for new talents. and to agencies around the world in order to establish relationships with those agencies aner allow MC2 Models Miami LLC to represent them in the United Slates Mir impressive qualifications as on Art Director and Talon' Coordinator. establish eligibility as to the regulatory standards for such clossificotion af o lop prolessionol in his field MI Brunet meets the 0-1 cliteno as an individual of extraordinary ability in the Arts and Entertainment field os wel as a business entrepreneur MC? Models Miami. LC is presently seeking a xophaticated art director and talent coordinator After reviewing his experience ond accolades, we ore confident that the beneficiary. Mr Jean Luc Brunei. will perform said function with outstanding sk i ond professionalism I, MR. BRUNEI'S OUAUNCATIONS AS THE BENEFICIARY in addition Sc Jean Luc extensive business qualifications. his career as an Ina-induce with artistic vision ono creative talents aucdires him as on 0-1 crken in the Arts and Enterianment Field His OP- encOmPrkslina experience os an Art Director. talent Coordinator international entreprene,- and business EFTA00599928 'ender in the modeling. fashion, enterloinment public iteations. restouanl and tounsm industries hos made Mr Brune' internationally renowned in those fields. Among his various accomplishments throughout his career ore the successful modeling agencies he has founded both in Europe and in the (fated States For example- in 1978. Mr. Brunel founded and grew Korn 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 Konn Models as o platform for marquee clients to obtain sophisticated public relations services and important modeling contract opportunities. Mr... success was so great with Karin Pons that in the next ten years. he fou ext Model Management in los Angeles. California in 1980. Next Model Management in Miami. Ficricla in 1982. Model Management Group also in Miami. florida in 1986. and Rebecca Commercial Casting in New York City. in 1988 the latter one was opened as o talent and casing agency for performers. offering services such os voice-oven television and cinema advertising work. again. suCCessfuly carving out o niche by which to make his mark and achieve bold commercial pertomsance results. Although Mr. Brunel later sold his rights to Next Management to Faith Kates n 1989. who partnered with Joel Wilkenfeld a couple of years toter. NEXT represents some of the most prestigious women and men in the fashion world today Star talent includes renowned fashion models Molly Sims. Doniela Peslovo. Audrey Quack ramie Diaz and Molgosio Bela. NEXT continues to maintain on influential international force in the fashion and mOdehng industry through its fully operational offices in New York. los Angeles, Miami Sco Poole. Montreal. Lae idor. aria Pars as well as its affiliates in Milan and Australia. Because of strong revenue growth and successful business performance as a result of his artistic vision os on artistic director and latent coordinator. Mr. Brunel founded the very successful Kcrin Models of Amerca in New York City and Kann Models USA in Miami Beach. Mr. commercial ventures in opening Karin agencies in Pars. New York. an Miami hove been extremely successful generating combined annual revenues of twenty five (25) million dollars. Eventually. Mr Brunel licensed the Karin name to agencies In Israel Denmcrk. Germany. and Spain. Mr. extraordinary talents are not only twirled to bunching successlut modehn usrnesses. but 0.50 in discovenng and launching the careen of some of the most successful models Mr, Brunel has launched the extremely successful careers of Supermeidels such as Christy Tulinglon Rachel Hunter. Sharon Slone Monica Belvcc. Estella Warren. and Christula Serrionnovskaya These women al proceeded to become some of the most photographed international cover modes in the wand. appearing an thousands of magazine Coven wortctMde ono spanning many years Asa (estilt of his iepulution as a highly visible. strategic networker wile cultivates and conduit- Is buttress in a global environment and brokers lucrative cleats. many EFTA00599929 lop players in the fashion and entertainment field requested 'hot Mr. Brunel function as their exclusive agent and representative. Some of !hese top former ancl present professional supermodels in the fashion field include. Naomi Campbell. Christy Turrington. Rebecca Romiin. Milo Jovanovich, Inez Sastre. Melanie Thierry. and Jerry Holt. 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. Jecn luc Brunel. Additionally, attached os EXHIBIT 3, please find several articles regarding the prestigious reputation of Kann Models as formerly one of the =leading agencies. Most recently in October 2005. and alter his reign with Kann Models, M. Brunel launched the prestigious MC2 Model Management worldwide with offices in New York, Miami and Tel Aviv Mr Brunel steeled the high. profile MC2 Model Management in order to represent high fashion models in a boutique agency setting MC2 Model Management s already being lauded by !ashlar insiders as "one of the hottest agencies in North America" as we as "prominently positioned to be one of the major players of the Zeros because or. its insider relationships with the most influential photographers arciurd.- We invite you to visit werw.mc.2MM.c0m in order to view the high-Cotter of models. MC2 represents Some of its most recent succesSki bookings include Uu Don', exclusive contract as the face of the Fall 2007 Guess Campaign and Sammy o I cover story for Cosmopolitan Magazine. Attached es EXHIBIT 4, please find of all of MC2'Ickents. including several high-profile Compagns tealuring some of MC2ilfashion modes as well as several press clippings regarding this prestigious an rep/table modeling agency. Jean Luc entrepreneurial spiral is not only contained to the field at ass. beauty. ann ian. In '970 as a result of his business insight Mr. Brunei bounded and grew Jeon Luc Relations Pubbaue. which specialized in press and promotions for tot; operators and restaurants in France. During his work through Jean Luc Relation. Pubis:we. Mr. Brunel represented various key Cents and collaborated on numerous prestigious events Some of the prestigious events include. Air Tour and Dora Voyages. Jean Luc Relations Pubtaus also promote° and marketed La four D'Argent a Ihree-slor restaurant owned by Claude Terrell and. "The Go-Between", a motion picture by George Losey. Other protects token on by Mr. Brunei through his public relations company was hrs work as product agent for Jean Claude Killy. 1968 Winter Olympic Gold Medalist skier. to promote vain.. Colorado in Hance for tourism potential and also drected all of the promotion for Ministry of Tovthi. In '975 Mr. Elturei further invested in the Food and Hospital', market by creating and developing El Mono Desnucto"- a legerdory. high-end bar on the Iberian Peninsula. This bar was known throughout the peninsula as extremely exclusive and attracted a ce.ledity clientele tine included actress. Ursua Andress and the Duchess D'Altda Attached us EXHIBIT' please find the Jean Luc Intel. EFTA00599930 ,mrxessive cynics/urn vitae verifying his fremendoi.r, accomplishments in bent the fashion ond modeling industries. II. ELIGIBILITY FOR CLASSIFICATION AS AN ALIEN Of EX1RAORPINARY ABILITY IN IMF ARTS Under the Miscellaneous and Tecnnical immigration and Nationality Amendments of 1991, petitions for clossifcalion as an Alien of Extraordinary Abilily in the Ms must be supported ny evidence of "dislinction". According to 8 CFR §2I4.210/I3fis). "distinction" means a high level of achievement in the field of ads as evidenced by a degree of still and recognition substantially above trial ordinarily encountered to the extent Mel a person described as prominent is renowned, leading, or well-known in the fields of arts. This evidence may consist el prool Pict the alien must be recogn.zed as being prominent in his field of endeavor os demonstrated by the following according to 8 CFR §214.2(0)(3)livt• A. Evidence that the alien has been nominated for or has been the recipient of significant national or International awards or prizes In the cuter field such as an Academy Award, an Emmy. a Grammy. or a Guild Award, or 6. AI least three of the following forms of documentation: (1) Evidence that the alien has performed, and will perform. services os a leod or starring participant In productions or events, which have a distinguished reputation os evidenced by critical reviews. advertisements. pubScIty 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 pub4lccritons; (3) Evidence that the alien has performed, and will perform. In a lead, starring, or critical role for crgardzcrtiom and establishments that have a distinguished reputation evidenced by articles In newspapers, trade journals, publications, or testimonlols: (4) Evidence that the allen has a record of major commercial or critically acclaimed successes as evidenced by such Indicators as Idle, rating, standing In the field, box office receipts, motion picture or television ratings, and other occupational achievements reported In trade Journals. EFTA00599931 major newspapers, or other pubBcoNons; (S) Evidence that the alien has received significant recognition for achievements from organizations, critics, government agencies, or other recognized experts In the field In which the alien Is e testimonials must be In a form. which eleallitates the authority, expertise, and knowledge of the 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 t ragroph (o)(3)(Iv) of this section do not readily apply to the occupation, the y submit comparable evidence In order to establish the EVIDENCE THAT THE BENEFCIARY MEETS AT LEAST THREE OF THE PRONGS OF THE CRITERIA UNDER SUBSECTION The fiatwegg that the beneficiary satisfies § CFR 4214.2(oX31(NXIIIIII. which requires evidence that the alien hos performed, and will perform. services as o lead or stoning participant In productions or events which have a distinguished reputation as evidenced by critical reviews, advertisements, publicity reieoses, publication controch, or endorsements. AS o result of Mr. combined expertise in fashion aria tourism. he decided to creole Latin Model Pageants. now known os Models New Generation to cross promote these key industries witn internottonat business and investment opportunities. Mr. Brunel hos promoted and 'edged various modeling contests throughout South America including modering contests staged Fel countries such as Peru. Ecuador. Brazil, Argentina, and Chile Conceived in 1987 tne Latin Model of the Works event was a high-end modeling and entertainment product that appeared to upscale internaliona' audiences reacting newly 400. million television viewers worldwide Throughout his history as a major interrioliono event promoter and artistic and talent coon:knot°, Mr Brunel has orchestrated rnulti.faceted pubic relations. advertising and media campaigns that incorporated television. magazines. programs. newsletters. and promotions. ing notabty lucrative for venous major brands as a promotional tool Mr ()Cute knowledge rat marketing aria promoting wits hos turned his vanous international events into highly successful artistic and busmess ventures la varous major brands Latin Model Pageonls attracted mope brands as EFTA00599932 sponsors such as American Adnes. Roy-Bon Coco Colo. Proctor d Gomb:e. and Revlon. Mr. has continued his ventures as both a promoter and panel judge when he founded and created the international modeling contest, Models New Generation that look place b Guayaquil. Ecuador in 2O04 Mr. Brunel sat on a panel with three other professionals in the fashion industry and Judged over lady-nine young women from over North and South Americo. Asia. and Europe After ten days of harsh competition. Jean Luc Brunel crowned the winner. Alyne weber. o fifteen yea old from Brad. whom os a result of coming in Its! plane 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 inckxling, Fashion -v, which transmits to over 202 countries throughout the gtObe. the entire Assodation of Tr ainsion ChannelS Ecuador. Notional Television of Chino and Rede Gloto, largest and most popular television network. Attached as EXHIBIT 6 please find several articles r rdit the 2004 Models New Generation Contest as wet: as the reading role withri this prestgious modeling event As a resuit of the tremendous success of the Test Modes New Generation that look place in Guayaquil. Ecuador in 2004. Mr. Brunel organized the second Model New Generation Contest which was held in 2O36 in the Ecuadorian coped a! Quito. In order to select only the very pest new models several 0relirilrary qualifying shows were held in different countries of Latin Americo inducing Boliwa. Panama and Peru The lino! contest was neld ,ri Quito. Ecuador al the historicist Ptoza San Francisco. Mr Brunel sat on a panel with three other PrOfeSSionah in the fashion industry and paged over forty-eight young women from twenty-eohl different countries from North and South America. Asia and Europe. After ten days of harsh competition. Jean Luc Brunel crowned the winner. Coto Lapna. or eighteen yecnold from Latvia whom as a result of coming in first place was awarded over three hundrea thousand dollars worth or niodekig contracts The city or Quito. Ecuador was also thrown into the internalonat spotlight as the nest city for the modeling contest. Again lust like the immense medic, exposure given In the first Models New Generator competition of 2004 the 2006 Models New Generation competition was broadcast cn numerous televis.on network channels including. ToSnion TV, which transmits to over 202 different countries throughout the globe. the entre Associateri of Teti. Channel, in Ecuador National Television of China and Rede Globe. Icrgest arid most popular tesewson network. Attached as EXHIBIT 7 Please find sevesnl press articles regarding the prestigious 2006 Models Nen: Generation EFTA00599933 Competition as wet as the lopn Luc Brunel, leading role within the event The 2006 Models New nerd on program was broadcast in over 202 countries throughout the wad. Mt Brunel has pertained and will most definitely continue $0 perform services as a leading participant In mode erg events which have a astinguished reputation and wit) bnng more pubbc international bight to F.4C2 Models For the above-mentioned reasons. Mr Brunel Safeties INA §214.2(a)(3)ftyl(B)(1). The second Dsonq that the beneficiary satisfies is LS12 fal4.2(0k3)(lv)(lili2). which requires evidence that the alien hos achieved notional or International recognition for achievements evidenced by critical reviews or other published materials by or about the tndMduol In major newspapers, trade journals. magazines, or other publications Mr Brunel holds an international reputation as a visible. shategic network& who is able to cultivate expert relationship management Skits in order to conduct business in a global environment and broker luclobve deals. Mr. Brunel has a long hetory in marketing and advertising mata fashion campaigns Throughout his twenty-five year career in the fashion business, Mc: Brunel hos developed woilawde exclusive modeing and cosmetic campaigns. Some of 'nese meta cosmetic campaign.; include: Bra Therm with supermOdel Erie mcPhersor. PHAS with Rebecca Rombn Christian Dior with Chnstino Sernannadkaya. Margret Astor vnth Monica Bellucci. Chanel with Patricia Von Rickenhelm. Angel Perfume with Therry Mugter. and Cachet& Perfume won Ado &Resit° Mr. Brunet has also developed mopr fashan campaigns and has developed campaigns and exclusive contracts with some of the 'up vc fashion designers such as Yves Saint lament Chanel Chnshan Dor. ci, Piada and Mac Jacobs Please see the enclosed letter of Claudio Midolo. President o' Moctetwori O renowned modeling agency (*Hatt 8 AS a talent coordinator. Mr success can and should as° be measvicia with hie successful careen ere models. whose careen he launched have achieved As slated above. Mr Brunel has discovered and represented various t uner models throughout he career. Christy Turington. who war. discovered by Nu Brunel, has personified unaffected beauty- representing Colvin hogiances since 'RV Turlington. as well as another model represented by Mr Brunel Naomi Campbell, became one of the tew supermadel.. who managed to mote an easy transition !torn the haute atamot tic of 'tit 9801 to the relaxed simplicity of the following decode Ilya:Jabot:O he, extensive career. and Os a reSull of Mr -lashes, Savvy Eye". Christy Turingtor t.as coxed the cover at huncRIM Is of 'ashlar, magazines such as Cosmopolite., w Vogue. Shope. Fitness. file. bazaar. mane Coire. EFTA00599934 Esqvsre. and even Time magazine Please see the enclosed letter of Alto Amontovo. Director of Figaro International Management EXHIBIT 9. In addition. the modeling events that Mr. Brunel has been organizing throughout the yea's receive riot only national. but also international attention and appear in multiple publications around the world. One of the mast 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 Globe Television Networks in Brazil. Fashion IV which is broadcast into 202 countries throughout the wend El Universe. CosoS. Lo Rozon Et [Norio. El Telegram Nanette. Extra Hoy. El Gran Gvoyoquil. Et Comercio. Semen. and 8 tideres to name a few. these major publications hove a large subscription rote which numbers in the many miRiOns of readers. Attached as EXHIBR 10. please find Several DIMS articles reflecting the prestige arid high circulation rotes of the above-mentioned magazines and periodicals which have featured and covered the modeling events in which the beneficiary, Jean Luc Brunei, has organ zed throughout the years. Hence the beneficiary satisfies INA §214 2(011310Ylial(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 jfiird atone !hal the beneficiary satisfies is 6 CfR (214.2f0A3levX0X4) which requires evidence that the aBen has a record of major commercial or critically acclaimed successes as evidenced by such Indicators as Mile, 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 pubilcations One at the main reasons that Mr Brunel has been able to not only survive. but also be extremely successful in the ever-changing wand a! fashion is his ability to 'identify and recruit stor-quohly talent. As o result of his ob:hty to SCOW ts. Mr. Brunel was invited to become a member in one of the fashion most elite and important associations. the Inlernotionol Model latent Association (hereinafter IMTA) the IMTA is an international ossociotior of Ironing centers for models and talent. IMTA gives aspiring models actors, singers. and dancers spectacular opportunities to showcase their potential talents in front 01 lop fashion and talent agents from the map 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 work, Several of todoVs up and corning actors and models bore been discovered of EFTA00599935 IMTA. some of these discoveries include world-renowned octets such as. Eljoh Woods. Ashton Butcher Katie Holmes. Eva Longono. Jessica Biel and Sean William Scott Attached as EXHIBIT 11. please find information regarding the extremely successfal and prestigious modern rid fashion association. IMTA. Additionally, Please find several pages ham Official websife documenting their discovery of the abovemenhoned A al actors and actresses, whose membership in IMTA proved to be the laurchirg pad for very suCCessful and highly moldable careers in the film industry Furthermore as previously mentioned. Mr Brunel hos launched the successful careen of many internationally renowned models. who hove been featured and still ore in many international and notional fashion magazines. In addition, his commercial ventures. especially MC2 Models. formerly Kann Models. hove been extremely successful generating combined annual revenues of twenty live [25) million dollen. Currently MC2 rs 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 lo mo:ntorn d for over twenty-five years. For tee above-mentioned reasons. Mr. Brunel satisfies iNA §214.2(o)(3)fiv)16)(4) VIDENCE THAT THE BENEFICIARY MEETS 8 CFR 5214.2(O113111v)ICI The petitioner has submitted a plethora of evi n regarding Mr experience in The fashion modeling industry. Mr. hos established MC2 models, lormedy Korin Models. which is presently one o the major international modeling agencies. with comb nnual revenues of twenty live million dollars. Only someone with Mr expertise and strong strive tor success Can °thieve such international acclamation in the industry and been able to maintain his status for over twenty-five years. Mr. Brunel is the one responsible ler the launch of numerous Supermodets' Careers. which hove been mointdred the spotlight tor several yearS. He has worxed with renowned fashion designers and photographers, who hove trusted his work and intuition In addition, Mr Brunel hos orchestrated many international and rational SucCesslut fashion events thul hove rece.wed International OCCIOmatiOn For the above-mentioned reasons Mr Brunel in addition to meeting of least three of the criteria of 8 CFR §214 2(Ot(3)(iv)(B) he also qualifies under 8 CFR §214 2(O)(3)(iv)(CI III, CONCLUSION It is clear from the evidence that Mr Brunel is eligible for CIOSSitiCaliOn as an Alen of Extraordinary Ability in Arl Met ton and Talent Coordnation based EFTA00599936 upon his meeting the eligibility requirements under the Immigration and Nature'dation Act i01(a)(15)(OJ(i) and B CFR 2l4.2(o). Mr. Brunel's successful corner proves that he is o prominent. leading. and weU•known person in the field of pas Mr. Brunet's extraordinary ability in the field of arts. in which he wit continue to work in the United Slates, hos 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 classificotion as on Man of Extraordinary Ability In An DlrecHon and Talent Coordination. Again, kindly note Mat the beneffdary, Mr. Jean Luc Brunel. has hold O-I status fn the post. Wherefore. for the obeve•staled reasons. we respecItulty request your favorable oducEcollon of the O1 nonimmigrant visa petition submitted by MC2 Models Miami. LLC on behalf of Mr. &unfit. If you should hove any questions or reciuke any additional docurnonlotion• please do not hesnote to contact our office Monk you very much for your kind attention regarding this mailer. Truly Tot/ff. EFTA00599937 Masa. sprabor It. mot4 1:363 vett Senn Castor 75 Low Writ Mer pt. mon VT 0SM-owl Pt at leon•inttworl Vim Males on behalf d i.e Lac tldkt Hent$-Raw Monti .tire this inter In Wrote; supps•rt el Mr Jean Luc limner. applitg:on for • noz-Immigrant Ile to rut country I am currently totnnaltratore Union In Studio P. I hoe been NW 11 review the prole- sienal eredentlolatiMo Brunei. add lo my pnefrazion.il optniop that Ma Broad H an aft Thislar and lair ri: Cocodinatot of extraordinary ability wbo ranks arnonx thr .mn II pen't•tia• et fan* Pmci• M lop d kY 1114/1 I haw arms firsthand Me Jets Wes openal expertise in the Md. including mart Production. coanimarica, and an direction foe amity 1ft Brunel It ounsidered by those in our helm to be an extranscienars creative throetor talent. portwuLub nor the Cana ad Blared try: .i.tnn In my perwmal dealings willt Mr. Jan La Brunel I found hoe to "r thorough') notional ad capable d to abed in CONIK1)14, with a wide range of and* subject to any mat intent. He bra Itte intuitive ability to provide futsi needed to torino nun with any partrular erealre prot and possesses omega:id *ethic sMatOrtnetd and operational skips that come from his sears of experience. Many people do not understand that behind every ace oertitg trot to and fashion shoot there are creative torn and who ate making tore that the basins. operate" efficiently by different tasks between photogrsplan ad taaisqpna SIAS teats I can honestly am that Mr. Brnel conbandly pent. hose tv. ap extraordinaro tint to his field. I offer an mandated ..4... mere be Mr. Jan Us Brunei /minting tin *a application as a person of rotraordinary rilery There la no clothe m dry mind tat Is popularity aid add) in the field soil only otallias to ptyelarr In sears tr. tome I • t • / • dtrlow ZIP • idtMPlie .711 EFTA00599938 Q/16/14 WKS Votert Beau Coati 7$ tower Welder. arms Matit: OSit•ti in; t SOL al alsioness ar aressen h. 1,: ? Sayer it NOSS Ds ar Mate I alit des Mlrr .n WS/ ouisport S Mt Janet L Brunet apphcart.a>n it a r tmeallptni OMw pet0011111174 1 an Cliftfley uwealr.• •• as Agent ell Tett 1141•11SID•ni len bowies David upon vas storozig a the Reid et tic authaan itehnine I es frequently ow to entente the anteater* A OtMe frlecv‘natt ra she SS 1 hive boa **id to nets piefeimorai craleattal• et Me .k.nr La Bowel It MI or 0Pallen. based upon me pews, sed preseistil iambs* of Ur Brunets talents* that be Semi •• an atai lifteltear of e•tnex-dinary abbe, eta make is% the Innen pa aelathee btslpl pirolnetconts at tea topples eetd. I putty kr Jean La. /Inuit end 'art pica ruts W sera sh 14.76 • Mk ad ems axed W taw tuts. proIle ataareee the Serra* Via stitch he elliptir', MS. Sam I MN eel the nrh taw orbs spercisses his Seto We nualrla: hate appeitlel in any at Ltw toorld• so popular publication sass mall ta.flion. et olteasso • puendeet totint• fur Hu *Mk M loOlrn, aghorrtart 'rad frtlar* sand ho COSIIINOXI 10 scar dim* suck em Cibta nes. Onset chew dos Is Swum! Ms • toots Yana af 1.1w lealond high ties an Seclori west talky. Ann la fttwald is tte cosotencow pestalenal yaw" It ems le %Ow me at bas c *id lie wolf a anal tall. at tt I sid• 1000 en elleneseent A bus ones S to rtnnmil Vd Y air esoolic lion of 4.1w etst on eve* Salad> Nthates It °nowt rai-rituinel• far bees etemenaation foe hie wet. be is RR worth the so Me Jew Us Brunei -1 lliqUralartriSliv •:. 4:An:tall aeon t mare lakni. tetlerwareval satonsene end ortwobcte t'.rn alhould ?ma Wm et Mr fr eest' eat madman stals. pies :c-ci bee *oretact see Thug web be Isar elms ants consideration EFTA00599939 ORECIKADELSTUDIOS vto swam big bee me PM, Nei t ?I 9371 weautenteannhethesis 9teteethwe sfr. oda Uri Vetter Bat Oar n Lon Violate Strom et. aged 0K,0000t St 0-.11tao-lamigrom Viii Pottlor o. Shelf ot Joss we Mal Dart* at Sadsov TS kiwi is written to at:wart the raa ap0Lcatmc of lean lax 'noel so that he may be actionlect O i ertnorditirry chitty tie trunnion:win= to croak aims Ise shady Oullititailaj SIMS ht Sr workbeklet hablon Intern. Imo*. hoemtlos )4 at.. rat Grog Kadad dthdlext, and bon idorbol with with dhoti a Vomit Ihthoitii Mere.. taidrvinv, Voiles OttodutttiFt5tylr. and Ahlure Jet tat drone) had boos thavat.etb wed mat b ow add as serneine *tat* rankle ad direct faltion width fat dhow, pfwv.-Ay:bets. eft Wt. Joao lax Strut has ■ trailed eye to whet the maw apprapeitth models to be used to zr. arhentang eatripaigt. and suistmx-etty has the outstanding shirty to manage all stars at the ennplex pewees of redwing the rat mini fre 4 job.Thertiors, the qtaalty bh :nrtliUtilt SS he la ebb, to !URIthe moo battik] VAAL Na result he le tag tweeting one of the.: p: dansmds of choice for the huh= twisty end other crummy inehattria to my opinion, Jose Las Dadd. s dandy a irdiadla d la aardloaty adt in the Reid of an. nod the peel ion he Win anuree !.the United Stern ilea* en:pun an individual d eltraoltarr ebaity :n tins !std. Mr. Miami Ism loam totdrommally krona sod rscoanstod for his uadqoa t ad erpettimc the modals he fin* nods* appterind to the men preettima fash:on mibilext ar around dui world at to EV* Mogan?, Cosmopokfun, Maya Santeeote. Me. &Ines aztProttoos to ma)ot dints have enured bans punkin° ea one of the lesethe &flea, and aloe omaithnidano working today. It is aka my oven= that that mrpnarbt:thes and dada (to Intorn.Y1 caul ail &wear, who collaborates with the mot dieing-Lathe:0 meg:mono. and atom, tains clLertt, locthe ea :n2rwie,al of extraorditary abfiltv and aceornpt:th::ter s sorb at Nr lee! LW Brut* Ilitnomert as 0-1 vim to oat Jo the !hatd Stab* Jets tat bumf eta math hen hit plienomeoal taleatto the air= out glee do riot Note to =ate meat ley goommts Padocdoo Maar EFTA00599940 Montage 4.11 , 4,4 fil. 4•1( IN ad 4," A ' I i Aie 314 f4å, aen toot Benke Gnag 75 Loser Waidam Stria aks Vi' orass?-oocri Ett O-i Mort-learnisrant Visa ~si at Shalfof Jan Luc brune Der1U« Malm- My nese is Contra mad l aa ['urdun[ of bikinier Malen. I bmw jo )van of experierice and lan <un stant in netet wtlh profasiaals all over the iretirld. A fro a ars arna in, Ituir Etle Mappe, %utelot !ekmatts, late Mfop. lyt ib v i,, Tha as} stum:. . and mo aa. stad[, t as qualtfled to oase ca Mr. Jean lar breane n aner la en ut dietter of ertraordeer. 'bie) It i sot tab- bause ot his acelaatiorii or lite nerve body af work tast beta adeste % and publishing ~ruin ei anane the world demt» stille Mr Bruner, great Mest tor ben tenowntd accturits. Mr. ann Le kanel ia ale an absolutt agert at foraishirig Ida diett" oie study Si hase of the" døde >ty perior4J1 apsreamtion of Mr. Brunet Se it say far nu- to reiniprreitnii hut acclamstions Frun tty inadNiate teer læ tetala Natt andinnsd. Acciorditik, Mr Brund b su a potes tar onetunesd stable anesten for ha stork as canyon} to «ben ia de Salme Mr.Etnil reputation asa ~e artet with a personal» det-manar praciadie ba die is satiody rearektag and devtioving *ilmulatinab' nerv amtpar for bis Ments ant:~ east to My os end irrit Mm sno bia *blik). Ove tS Lue .:! hås °definert! re, Jr. n Lue Rrtmel batt cbti~ed ~storr id the lading tam an &stor ia te Shatry. Mr. Jan Lat Brutal enjoys an extrakirdi Mationship to eo. -3<mhr ne. nå. quellity ~res kisel ~sti the breatiful *ork Pr crea tys, Sev Idblir tet Therefore. Jaa Luc brund i sir . ont rf the moet talane, proffe støla ~kn in tar worid tty I bok forerd to sees ttl:,re of his wca i It* kaun. elaan/y 'to" Made Cannot* Ner EFTA00599941 NJ< IR 11(1. )M 9•9~ 17. 21)14 USCG Versant Sava Ceram n Unit bin arsat a ~Pk VT od4790oot RE. 0.1 kris enegeni Vas Pei = on bode of ais., Las grunt On: Si wean, I «quid le ID «tend rr, frien uti~ed augport for the adMardirery airy 0.1 Woo pennon sarthiat by kr Jeen Luc Bent As the Sate relent Praha kr Nixdstrorn, ten qualaed la say Mel ati Joan Lia Bane leaned duelist ard beam avameor or is Namet giber lease Menniair mieerlencs end awaits Mon Nina Mt tite U% the 10p ot ha Motaitaion Throurr4 Mt Jean laot Brune* &gimp uished career, he ner rg..cccvcd a nigh), tmgreashie fat of probrebonal ham,* and achterannts M In• laset Wit yin Ph BMW Tao GOD u led beautiful modal dud have espoimad Ins hi of acclaimed projects in NMI of the most eminent pubticabons in tat rala. Which anus as • testament his ten I awn e cane!~ trints to fie ~We and operational aails of many CfC1144C ant°, pac.paa. Inoludtrig an dins and Wan eaardinmon It M Ø-Z; Mesa la mix.; ritak tha rennet*, lawn at schwamints of Mr. Jeer tactical-sit µa ~apt to *alien it* Andregest mutt from the mat ant" developed eats:a conciiptr. end icka II he his vely Lrlique tat/to:11T~ t%i tareft4 'rabies, lhaa intanda.1 melee ~sags of ria ~tan Maw that Air Jan Luc &and at Waned he ~end is swage lanio tor Qua ham« by n Eunning monl wilh nil in wadi considered indoor& nu nil Worked 44/1 wino of Me Ontario« Sitars• fashion home, and magazines It Ira wormer., saran ~hirt %IS« lam it) Me rents C Ilte wly beet In Mil praise I an catdia/7 astity tha Vt. Jae Luc own ridmiallen schevad irdeminkinal strata tie has retched a Ina( titre initistry Meese now Smarts hen se a 'age Jaen Luc Brunes tdranidtairy eater fl ame< rive glen 4 "re timing both Gin. Lin Mate ~Tani F,odt.wxr NOtti ii•• S I. lei . Imo EFTA00599942 Recommendation letter ra/09/14 tgont &WW2 Center 75 Lower Welden Street St. Albans, VT 05479.0001 RS: O-1 Non-immigrant Visa Petition on behalf of Jean Luc Brunel Dear Sir or Madam It is an CittitMt pleasure to write a letter of recommendation for Mr. Jean Luc Brunel. I provide this recommendation based on my know•ledgr and experience in the field of modeling, due to my established reputation and watt in the field as the Vladimir Yudashkin. director of 1 Mother Agency. Kiev. Ukraine I have known Jean Luc Brunel proiessionutly for rieveral years through our work together and, in my opinion, he is an extrfrmely talented individual with superb professional reputation. He is an!extracirdinwily 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 abilat} to recognise the creative vision of his client within the tune and budget through his careful and thoughtful choice of model casting combined with his meticulous ability in the field. Jean Luc Brunel is a 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 successful career. Someone overflowing with talent as Jean Luc Brunel 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 tic, contact me should you hAve any questions regarding this matter. Thank you for riiur time and efinsideration Sincerely, Vladimir Yudash EFTA00599943 FiGaro • selp 3 88888 •P tell,*111 .)2 re OPT. NIS •.*•4 ur woo ••••ALOPA . 'I..4 OM 110119, 34.. , Department at Homeland Security United Sa. Cillanahip rid Immigration Seem= Verse Senna Center 30 Hauntati Stint Saint Album .VT 0$470 Illesebor 0.117ellel Iona IT, WII :WY • 01 reareartfletary Malty en een Art atectee cs Taint Cocettnafoi on bettor of Mon•lue War lippett•Rore Inapt tut% Owe .1/20p1/4-(1,r4. allta se"ey r eetr4-4-4 "•• :el In I na +lib ter' sr.-4 .21 Q.' &.' >licks fen l'elMent ',,s1r1/21C1ralte trital . • 2 COOldNeelle4 /A. Olean Vs-cell ..;3-• oreel ergs° De i-rerstureil wor% Inv a cask,' caret, Ine mak* cir•ein h* MOW r4rj leave 0. 411/2 r arte not jsc:.ir ipj 0:3 natananied nairax •,:otv model thoopsw7.,. ",..inialon. pox, ota j ,nzi pr Pdv Grow nal persanielai inarectita Deauty 'ACiersrling Coin FlIelfrCe sitrcrt.'n Wilt 967. lio•IngeOn Ciremrsee Mg* •1/210.0141/2•00 lee eVe Ilre%0 toace1/21/21C.:rnobel. Or.O•net met MS POW illorriadat &'. inOregal 11,.(C cr OC:ri le-nror.Pre4 *It ria0.14 '1.410 ”:":0 • 'Ffit 7 93C't tea naiad trent si Cr Inc 0:4)-K.--a 1:a-'EIS )...,pa.t -Moth Vv Care' -I: a nave cr u. Aar a 1 anettC 43 SZI/s4-ei Fri` Ctn.'s T.x.rierzere r.o. tor Aws thio ; 0%.*. 1/24e-crece. of 37/0", 1/21/2:30=nat air : ;;;;:.11/2ze.cee.r. es ra,y,a stabs grim pia ft:e=cer Le.cre Cie:MM./40r 1. 0.1-ler aria vier • Ft* arairirreP Nu Sure rem %fly etel.`e.••••S r h •Sin t•r /telly *mid ref./ten Stone. vcrir..7 aiettxr.:1 fret* *rt." *ant 0)frecttatasti ber.‘Mvis 101/21/2•3( the re • • • . trio ws-1/2. copect ye artookullTe Ot/ re09%The1/24, c .. • ' 'tic' 4.1/ " 1/2 •efee."1010l W. •r 'y-je/v intio - _ cijouy;; r. O 900, ante.), rimy t 4.1rdiVtitecti.0 .11 • uf--.7-2- - en• feed .0).090.c3 'net W Maar 'sr .0 Lent -ea ter-. t(. • c.1.3 Twee s .ro' trrAi *A0r 14:0- .: 0 "a" r 1.. ,3131' "'II "AnkShr . . !•• lriCeer• Ain Annentny.-i Ofector amen s rdperropies loci- 31 forriel rill CitarC ler-r-rec.razta Inn Wuttimsc rtee^aMres cove. wan^ A-Aclosor. Wei TOM lilt— r? flt3' A% .:4 omi ell - • .it. We -0 CV T :. aria ......at,:::: WIC( '1 UV * t, "It Ofrone. *-117 I Cif ,ter ei4nnve oper, lr...% ' 4 /e ft rst seCr }tires nits *Weser •e* "tin!. le'-j COrotecl • "C. n the 'Ir. ter; EFTA00599944 MODELWERK MOD1.1 tt.i.% 1.s1.11 P en '4 1 '0 'LI* •••4 I I s. /1. ' —; l• • II .443.40-4 1L, „ 7. Hamtxxg 8 Jcy. 2014 Deportment of Homeland Security United Stales Ciburiship and Im-rigroi!an Services Vermont Service Cer le- 30 tst-Aightor Sneer Sons Albans. vt 05478 Re. al Extroordiriary Atiiity as or Ar- Dime tz and -alert Cr>ordinatcr .:.n behalf of Jear-LL: Didier -renn-Fter,e ?rune' to whom rt 1V4t yr, Concri As a President 4-.it Mooe!werk fhb letter is Ritornello() in support of MC2 Modern Miami. ..i.0 or behalf or Mr Jean Luc Brunel 'o work as a- Art Directs and 'alert Coo-airier:J. M. Brunel *RIM ri7P-00110,* ci a vilbie. shatogic nehvorker who --. able a culfivale expert relationship management sk order to conclucr burtess In a global ervronmeav, and timer lucrative deals. Mr. Brunel nos a long mancerng and adVeriisng mayor fatilon campaigns tnros.gtto rt rir tweniv-five yea careerlin the tor ,:n business. Mr. Brunt has developed wo-chvide. exc.usive tnodelird .rlo con/lees conpatons. Some of tese major covntic campdans Bra Therm with supermodel PHA with Rebecca Rant -. Christian Dios vain Christina Sernctiinovskaya Astor with mornico Selmaa. Chanel vnlh 'kJ VW:Ili•_xeru>eim. Perfmkrie Mugter. and Cucaotoi Perfume with Ario balle,stra. ho i a:st• developed moic- !ashlars cc:m n dove, r. and nris dov r. v rr vied ca.paigr *Ira WICILYSIVO ccarac is tone est the YeatniC IOU IMF indeStrjr EFTA00599945 Yvtri S i! O lotten, C h imt C rir:sttip•-• Dior. GL:c a. 3n.: .varc ~Obs. In addition to Mr. Jean Wc brunet t ererisive business CMICOtinfir:, us career os on rnarvauci with armtkr VS10(1 ana creolne to nh hOs nelped him frid rop fasolon modets to rervesent ir the United Stol $houid you have any ~bon abOsc :roe „JC Bet. ti I q‘..:alit cor cr:s leet trea to cortact ° i • Pk rist SlI ined`,V€ISk. P i. r ic eltitt4N•M It prcsi.(1)(;;P4`. 2:: 100 Moilelwert Mildelhgettlin t «hl EFTA00599946 «cons ibte,•0•• Ant 2014 1:400tittent ot Sornrona Ssettity Wined SØ Clitienihip Ø Inimigionan Santa:et Vermont Sonic* Cr.. 3D •Io4)6•111on Sim& Saint Abase VT 05478 Re. C}I tottroctetrxxy Atitly as an Nt Disetot and Talent Coortinat.)r an WINS ot Jaan-luc 0tt« Heat-Rene Brunel to wirene may Concern As a Pnistaent or Natalie Mods; Monovemont the lone b %trolled In tuPttort al MC2 Abash Alorni. .1C on Dorian at mr i an tuc &vie rc watt ca an Mt Drec tor and fawn Cocrdncrior i fre gainel holm an i^•ornzthonol mputanOn 01 0 snit natoGic nett/otter ~obeli. to cuticle export reIGNeelnO m0ot9ttnent skill 41 ~sr b ~act ~Weft In a Qi000I onvEinntonl and Isteltor loathe deals. Mt Sue has a long rosary h nksiliang ond edverisirg mck0 t lames canynuns r•woughckit hls twortly-We yin cue« in the rashkin tvårisa I* Rene har dnvoloped woftt+nde e0rCL17Ve rver/d.3in2 <set ~sic campaigns keno at Awn mite cars& campaign.; inciter Bb Nam with tarrnoefoi He Ptåttlersor_ PIUS with Rebeeco irOmiirt CØ Dior with Cridatina Sornannowlaa. Marcret Astir wAri Monica Beata Cht:Cal wfir Patti, Van lattentettn. Angell Perfume with Marry WO". cnci Comas Pettuntt vAlti Aldo Bones, fa. Mt Suns has dso ClereSCI RCP rashian Campaigns. ps cletrolopekt carnpolgrn 0nd emcMhe controch wth tome at [he top kaftan degners such or 'Nei Sabi latent. Planet CØ DO Goat Prodo cno Mac J000134 - _ _ _ 5 '&9*^%dr4 Mani Il• wan,. +b 1LJ amp tv 5441 lafr fr s‘c: 31141 I t' 1,11 1411 • pan flaSieeri• •••••••••41,14•TrL .:Alta a, J 449 ^ /1%24+. 4'1~105 BANA axis WAY!, ...tr.s :2%. -ARA .}.).,) rob MG EFTA00599947 In °Ono to PA. roar Ric ~Ss ~ow* ~nos Quali6c Litton& ha eater as an indlviclud vat arlac Son and anew laenti Mai nebed tarn add toçt, toy~ rytodn !ti mane/ in the U'►1cd Sectes. Should yoe nave any quesions apart fl an Luc Mound *Kith aftrint le& tee le contact it.. EFTA00599948 Men. Seseredier r0. soya USW Yenning Somata-me vg loner Wekten Stew( St' Aibwis•VT*5470-com Itt 4s Non-irrmipnct Vbas Mara as baked of Jean Lac ind3cr Hand-Rene Brunel Ivithr Ibis letter in strong sc;:port at Mr Jan Lae Illtsiptkaian for a non-immigrant Ha to this country. I am curry ilniviratore Unto, in Studio Pp. I Arbe been raked to color the profe..innal credential% nt Ms Bryant'. and a iv my professional opinion that Ma Mimi is an Art Dineen and Talon! Coordinator of attalardinary ability who rants unarm the small precentor of forams people is seri. top of ht. field have Ma firat-hanal Mr is vparinl erpative in the field. Including caging. production. mot and aft direction ter data Mr. Bennet it mosiderrd by throe io our Wintry b be'an odraoniinary cry-alive director talent, panto:lob tor the (ashlar, aid related Ineetne. In sty personal dealings with Mt. Jess Inc Brunel I -found rum So be thoroughly proleadons'sad capabk of briny inibaild in ennonrbob with • .ride range of entire "Akin-I matim an any tainnnlrot tie bat. tee intuitive ability In pnnidr nisi palae needed in toren wib am rt pa icular ursine procem and ert s excelitat reenacrtorn1 3rd operational stun% that tome from his yore of experience. Many people do not trader/41nd that behind retry ascte4u1 relives:, and !Wyn, shoot there in creative UN TI and our who sit nuking sure that tbr buy:nets operates efficiently by enordimaing different tasks benren trodids. photograph/es and menacing creative bran I can honewly wa dial Mr. Brunel cordina pots Int tt In extraordinary. Worn in hr. field I Colgan menitigeted codorsonent be Mr Jan tax Briny! regard:mgha visa application as a wean of en faOrdlliary (Miry. neer is an hurts in my mind that Ids popidarny and story is the field win cob camnut to Per in tan le e I r it ether tn. EFTA00599949 q/16/14 1.3301 Vennont ~ss amor 75 Lowtr Weiden auttet a Alba Vr CtS4'79-ottu Ra af Illoneanat ',erts dm neb: , ni Jolen •••• Ons Der tv tur Madam *nat Hts alter co nos support nt lir Jan Lu: Maarts spplrat ca klats. ~I *reit SI b thill sur, ~b soriing dig OXIMOaa a lueu )4ansarn.e... a. Lat Angeles Deed tapen tv ctane.ng in the Zal iif tbc baiban indult" l ab f:eqt..ea::.. OOM in ~al» 4v endontS15 d n:her rrnlettv•-mIt m do MA I h...1 Na Migard rerlet the ~nl ~ende dr Ms Jean beland II is or Frektitugnal OPtr,. parinead and prtdstaitend anorindor of Ni titwtel• utents. ttitti 'Ir Wad ni Os SI ~ST r•In.sntnany SOS sta rwas ~ni Se *mail parrEtban ei bilde prrtialon2:1 at win top at am leid. I greally Ild17,11T Jan Lu, drumt and ut! e a V;-asar to star., tobt bril • biorod Prisl Judgriol bv d'r high red`Je ISOSIM d :he t.tppamu. sak ar.:n S mulat ▪ [lest, I In ••• ambo appnrcleass bs talmt. Hts w.cdclit' have ~si cd at nop albe werla• reet putkulat putintokans. matbad ~Walg 3r .deale git is puttabbst tags T. etea Ob Øm:: and rtirrtrl 5.41 tom contrIbillOn 10 babi stanza siela sa ~a Whin, aneol. chrisma ELS Sar anaal kin; e paggiggi as ~Sub, keradins ladtuin art ratmnrs ~ramt tdd3v. ban ls Itraciel Is dat arararrinta:t inablennal nalia b tbr en d kabaal lIndM. Net la e et diigpisiml Ir. Nette SS rm. wigi~gg A USO aflaat S ra Wal Ca Va INII~On d i» clas os nor) sinsadnon 0S~å 4r Onenal rawarnananp tbr berst Of Sa sst. S ta wel/ ~tb the sst Vit WWV* -2 un.i..inilaiit..14t .r.iihdeltial Ot estriorthaart •ng rit. emir.. ialgelligitigeslaSegaisnit .ns ~I/ st. Sin er gsgMionii tip) d.i.« /ir Stand • sectrocrdaairt abOS, plas fec. tree to contact se Mank sr br 'par netme anu tanalennon EFTA00599950 OIRECIRAZIELSTUDIOS iseds titers me al loan tal a Wm IMORITINFAISWEIJOI011esai actosibe *Woo USW lemoothrloo0o0or atone Wohinatter ItAlhormin 0$00-owoo IL 04 teasesolgtwa win Piton es bohalf anima Lc Intl Doak orliedszu no SOW is written to atipcort the visa nviczArt of Jcza Las Inaba to that he may be wonted 0-i wamodhawy iX Y Ins sous b continue b cpad stet S already ouarnodiza as* la die allabilith baba Inc. chm Imo tho Proihnic• Menage, at 0cft Kral Slid's, and biro sorbed with iodi dim* as Vcsiur Italia, Kurt Ildevises. Vogue Promo, /rimy* and Mitre Jllm gat nia has Winn nuns may ma moos is OS eat as arreecte who at Salk mamas and dist fashion onaddie S diem; phoutraphers. at. Jar Luc /ma hos • trained De to idea the =at approprier models to Sc mei in an adwirtiaingaunpaga. and Stsequendy Kan the outitaaorss try en mauve- all wise nt the eceopko pions of penduting the right mart fro a jab. Thomas, the of bit si irk n incrw'eble a4 hr la aStn slag the sit hearuLlitil MAY. AD a rota be beceming oee of Om Frrotemon az of choice S the faahina incisatry and oast: name iodustain. fa nir opinion, Jon Las peed. o daily as tradteithal dmlg ature obikty ts the lurkd of azt, and the vaidtita he toll seatme is the United tinny recitoms an individual of retraceshneni ahl iry tr. this Said. Mr. Ms/ low Ins istentimmtly Immo Aug plecenned for his ttathpe tastes rd eeleeniee• the mash h. fine 10.11110oppoonog d lb, most reatigkes fashion ralICIMINIP tie worts mock to at eeopewOo*, thapowitiow, Mayo. ticedstoso air. Brood's enetribmisas major dices hew secured him a position se on of the koalas dinettes end Wet cosatestan eseekiag tole. it is alto my opinion that the responnbaines and dsoi.z clan nternanotta/ art eacur. who codas/tee with the sat &atingulaled nutpxtrin and adiertitin da tocsin as minid maracodioary the:O• and tumn-iptthrista such as Mr Jat Luc Road. If gnestet es 0-1. ilea to wort it the (hind Swot Jam Is l000d mob Wag haw pteeocomed tan to the Awe.= mats Pima do oat fl at to mann me old soy once tart Pcdoike Maw EFTA00599951 montage 31/2 1S1 tJ,CZt.flr Os O. NM IN i 11 • I , • • I 1 N. II; )634 VS &tyke Centel Is later Wddni Star M. Alban, i/T two -cool Non-Immigrant yin Petition Go Wallet Jan Luc Tina* Dior Er ce Madam: bly nerne a Nadu Conan Indian Pe _dery al Montane ',indent kw 3o flare &expo-lcAce and I Mt CLIP itant;:v to COMIC! with peofesoconan all tionov r ant the %vrld. A diens in,iii.i? Me Magariae, Simons, Riamans. lam Sop. The St) S SO an. Art 'Lica I AD qualfted to oa Mr. Jean la maw as en art director of extraordinari. ability It is not ally because of his acdarmations or his knpraseive body of work that laltion advertising and publishing nannies armed the rigid dwelt to nine Mr. Brunets greet taints fur their frOuwatni accounts. Mr. Jean Lae Brawl is also an absolute mart et furnishing cis diespi with fancily the lenge of their desire. My praon21 approquitin of Mr. Zronei take is wry foe mr to cninpn-:1-1.-nsi his acelasations Prqrrt my standpoint they an certainly wet asollassd. accordinny.Mr Brunel Is it a peoltioit to cortentend sizable ttimptitistion for hb work as ampere to ethers in the buten Mt bunt* repo ution as 10Cinidabie ;IMO witO a permunabie Cialneanor precedes inn. He is constant)) mean-1nm said dentioneg stimulatingly new coompto for ids ribette and I Ant mat to my on and mut Min and his ability. titer the route of Ma celebrated career. Jan l.tw Brunel bat dinioguishod Wort a air of the SIN lobos an directors:Etc industry. Mr. Seen Lae Brunei crjkiys •A extrsordiesr, reistionahlp to the mithrtir. This quality tasnliests itself through the hewatiful work :e• crafters an idler WAL Therefore. Jac Inc Brunei is defy one of 11w most talented profession* working In the wend today. I look forward to snag more of his work la the inure. 4/6 "ect-.-. Nadia Canova EFTA00599952 Nos° nel )m tkeetest 17. Mt M8C18 Vernon. Berme Cedex 70 tereelAbidien 81r ail *Mena Vf O5479-COD1 RE 0-I Nonangiornt Vue Prion on blêmi of Jean lue Os. OMS* or Idadorrr learld lm lo land mitard uneueened support fo the beeardowity stdary O-1 On graben SUbnited b% Mt Jet Luc brut Ru th, Ser rident Producer fb morestrorro am restered te esy ter Mr Jeen Lue thune! Montt *bibi sud béent oceranebr of ma Ness' net* *gon Mettra recretbnce end usera rite hale Mid SM te thO lop te Ne preeemiert Thrournort b1r Jean Lue Brunes derçuidied amie, ha nie retend ■ highli 'morasse bet of profneonok honore and odurreceno In MO pan Iew ms& Ph Head tee etouied Immutiful modes eut han art:morte In s lm d rialair:ta propactt saine af et rosi minet public:MS/8 tn doroceld tale atm os il Ictlament to Ms Sem I en e contient Mines b fis erse end octerrelonal site af rosny cmat,:r drezeen Nicole, Moines art adore end irisrA tenornoen h M leinlbro ry piaule b remordu the simineable tes as Suavement' of Mr. Jean tuo tirant lie neigea didikree due mraneest rotule hum the net ardues de-TeeFei creelhe concepts oral Mas Rb Nb very indus +bibi te °conte-Me, wa tarefd arialyet. Vis itorwiel «MM message of hie (Nota. N . Oser t.al Mr Men Lue Grand lu !Santal fa yole ths average ente tor Vue 'faner bp erunille more *Rh •crece h» werk. • contage Indeed. na ha oorkwo een fore of the blegrain raton bous ad ruminer In be %rond ers recul • stade Met I place en ta -éinii4 Me veey be* In rte reflOISOr I gr eerMently Mebty thel Ait. Juan Lue antes neusnon nec achanti meemets" I ta PM Me reetted s levai orne Suey bedon ne« douta hikt es e %tee Jar Lue Munit erlreardinity carter le et e rern **se bers s réa torning bec, eleonly. Lira Mach 4) Omet Tobnt Producer non:torons . N'S •Ii ton. 1v it 104 l‘s.011,11Iej • •- EFTA00599953 Recommendation Leiter 22/09/14 USCIS Vermont Service Center 75 Lower Welden Street St. Albans, VT 05479.000I RE- O-1 Non-immigrant Visa Petition on behalf of Jean Luz. Brunel Dear Sir or Madam It is an extreme pleasure to write a letter of recommendation for Mr. Jean Luc Unmet. 1 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 Yuctashkin. director of 1 Mother Agency. Kiev. Ukraine have known Jean Luc Brunel p:olesunnially for several, years through our work together and, an my opinion, he is an extremely talented individual with superb professional reputation. He is art lexiraordinanly able coordinator who strives be and attains a level of merit in his work that only a few of his contemporaries meet. He has the abibty to recognise the creative vision of h:s client within the Ulm and budget through his careful and thoughtful choice of model casting combined with his meticulous ability in the field. Jean Luc Brunel a a 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 models in his successful career. Someone overflowing with talent as Jean lair Brunel should be given every opportunity to work in the United States where he will have the proper venues showcase his extraordinary talents. Please do not hesitate to contact mr should you have any questions regarding this matter Thank you tor rum lime and consideration Sincerely, Vladimir Yudash EFTA00599954 $$$$$$•r 1 . 111•11,i.•,: .34 r•Zit 11". SS Mae • ..‘• Kr •Li. WM ariersori Mower 11117,*1 Mr* 1Y Me • • -"Its 3/4 1 Doportatont of Sontotiami »curdy United Stain Citizenship arid Immigration Sworn Vermont Zeroed Cos 30 Houghton Slant esine Aihans. VT 06478 too. 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O-1 Extroordinary AtiailY os an Ar Dir ce •ce and 'alert Cocrdinatcr :n bene of Jcsar-Luc Didier -enn-Rene Brunei • To Whorn moy Conceri As a Pu.rsicienl of rAccerwerk. letter is sucre-mea in suppar- ot rAC2 Modets Miami, ..I.0 or Pend, ot Mr Jear. Brunet so 'Io!): as ar Art Director and talent Carinate. Mr brunet •iolds an ff•teLnallonal repurollor m o visble rotegoc netwoeter %ex) obier 'ci cultivote expert relationshrp management ;1,.''s cxcler to conclue' business in a global erv•rorirren• and Noce( lucrative dents. Mr. Brunet nos a long intory n martien° and adveriwng mare lotion compote"' ttvoughc...it rus twert-live yeear careedie tne fart n buStness. Mr. Brune has 0evelopea wo--Cwide excwsive inecleliN; and aosmetic compares. Same of Irese -no;or cosrnenc incrtipe Bio Therm with superman; Elle PAC"nersof.. I'HAS sor In Yettecco Kornras. ChriStIOn Dia with Chassa, Seretoneloyteuyo Margot Amr with Vorico Bellucci. Chanel vire; Pollit_••1 Vcri Rtr.kesititirr. Arge- Perturine eith Thiry Magler. and Cachait 'rlume witsi Mia ballestra. mr. &tee has alsu deveiopect major fashart currtx”gns anas (los asve r Pod carr•Paign ord excluséve cc—Irramis ...yrn tir.-nt. of Ilie 1 .IS gale' c>n ciesipr•cys luth rvi EFTA00599956 Yves Son^ tov:rla Chanel C-tristion Der. Gt.:c ;7••243/3. ana Mac 10cObie. fn addition to Mr. Jean tut an, extensive tin4nesi career as an anarwlaan wilts entity! ,,,,ar>n ana Creat.4e to him kid tap famon models In represent Ir the United Sto I OtatIccartiorr. nh hos helped Should you have any OtteStbOns above Ma JeCir uc Bari I QuubbcoLcris feel free to contact me. Clilimilii•NItdosb PresiAlm"u Moitivinictilon• t ssnhS EFTA00599957 woorse ibert - 0•• ~newt cd nornmorxi Security United States ClitereNO and Invnaralton Swears Verrnont Unto Center 30 kovohlon fl ee' Sant Alan vr 05178 ▪ O-1 bdrinclnory ~manna Ø1a and Talent Ccordnator on beta at leallsluC :ASP( Senn-Rene Brunei WhOM ri May Concern As a Preedent Ot ~CM Ina letter is sLernitteo soarer or MC2 models kisprn, bercrt Or Mr »On lUc auer workman Mt Deeic tor and Tome Mr bun« hoick CM ntw ngrxstallitan 01 0 visible. IS ninny:nor ena Is class to cullnlee ear, reiononsrip manourrnens skei in ortfa to concerti Wens n a global renvionrneM ond Mal* Warns diet Mr kunir ha o long net« n rnartelhg and o2vriseng 'Wept lothIcr pOrrppPy Tnrcugho,-1 11Fe twereyere yea career In .IM foshion blikboli MI Brunet has des ebped woncriede. excerstre rnadatno and cosmetic carnadato Sane of Its. mitt aqk CornPolgns "rant No therm with swarms:$.4 Se mcffierlOn. with Rebeeto Rain. ~an Dior vie CtektIna Seeman:enema. Margret Astor yen! Monica Baal Chanel with PetliCkl Von fact either" Ansel B rumeyel1ti Thien M e. d Cadent an Patine vAlh Aldo alsa. . &run& hm also arretopted "11Sr tcarilon compg.Qns and has ~eloped campaigns and iliCluere contracts with Ems of rrc weals tap bar ~on ext. us Net San, tweet Chanel. Canon Dice Gucci hod°. al Mat ~Oa 'Aee•nrurs testes hatnaia• tea ;ro flgro .Y.1011 'sta.} Ise sail at, . u' rat 4411 • pats waimil iPt , ' "en' " nl 09 aa? WS:Ceiii4U4t. 43 Øy PM». tOa 101.1UPaY1.1 flirt a% ~IA) 20O2 410' EFTA00599958 &I actin7-n to Pa. JeOa Luc, gip *votive extern brands 1.0113:111tahnm he WOE O$ on hdivIdnai wft •400n and t has head Mint Ina toe fashion .riaaets So reixesont it the Untea Slates. MOM Yee tab any Cluegans about bk. /Win t*t Mk* guaitcalten Mai xoe to °Woo fl s. finCanilY. Erk Mahan% EFTA00599959 Vermont Service Center Attn: Premium Processing Unit 30 Houghton Street St. Albans, Vermont 06478-2399 Facsimile Transmission To: LUIS FONT aal= Benton Fps "ton i sum 4272 Number of pages including comic Date: September 6, 2814 Prom Receipt Neaten Verrionl Service Center - Premium Processing VSC PeLestA1 PROCESSNCSD9S Goy Fax Number. 602-2681TTH Phone: 1.8W-315.5716 Matted you mil firn a cqy ol CU Oec-scn concerning you case The orignal Oecesien vas blow via mad If elgOle to appeal ow demon epicl bins we be include' —lrnpvtarrImpatanrimportarrimpetant" If responIng b AR/west lot Evidence or not to Deny Insure you nclule a copy d the decision lame:Maley kiltraing you we page and aka the long mister d pages included whet your response Please include the case receipt roster (I g EAC01 CO3 1234) with si ocaespolerce Enure seen raspronding to the request that you to sus response to our NEW FAA N UMBER - 802-20331718 If youwsh to mat a ressicese t meal to eel to tut VSC Prornurn Processing Unt al 30 wocgrion Street St nuns VT 12428-2339 Do not sand ycur response so the 75 Lower Weben Street addess. as that w:: case delays and es rot Mar IM patellar MOND% dock tat TM response 6 DP1411114 all a pleneUM prccomng case tea 8 CFR Setton 103 MX 1 Sutension of evidence in NSW*e to a Serves request stales MI eneClence semtied in repose to a Seco nest must be sttmtted at one time The Remission or on'y some or the ire,ettsted eidence will be conseeed a request bade:coon based on the record Tb careneatee n Melee kr The wee 0 eine neiveleello trbom en Aiello sternly teMlen 0/0rtnelle0 PM n mama ccedemeel 4,41 tweet, can emblem ender entebe a* 11 be Naar al nei coinsertsben 4 reel tee wended melte el ea bmense a 40" &heap ne orneacsion b es stead inpier4 yes se limey Whet MI fly esiasailled devisees a mere Mae terenneelleal my be wept safest, II yo Maid i.e cerenuneflan P 1401 Om edgy lee under misdate* by timbale me Mem eo, enneuncalaw el ma edam mow es thew Sets PeelsiSecese flea tau wwee.uScisnov EFTA00599960 I U Dcputerrni al Hone land Seemly UGllarnshlp and JR:III:denIlull SCIVIte) Next ed Atlan Teprldl ApplkentflellUceir A f Appl:cmon Frew tree Fenton For A Nondratmanl Waked (brin 11291 Nair., Oa Auktvkl Z6 414 Ronnie by Newnan II 20le Ha MOORS MAIO ;IX WO re« TOM TAW MVP FA %HU MrlinionTID Et O Sri Ile nnuaveo n :An ; fAeppluent/Petainec u NCR MODELS MIAMI LIA- nel Loan. IMN4ft /FAN LUC Prompt Number EACIliiSSCI03(1 I [el IMPORTANT Ills NOTK k COX I AMS YOUR LINplit NUMMIC AND MUST NE SUNNI I 1 ED IN I I It ORIGINAL WITH Hit REQUESTED EVIDENCE U Cturtatirp and brume:nun Sena tIJSCISI reline attend evidence In pOng yea locus Herne monde the «Ain* bawl ea the alga ha piano Fed Fenn lilt cab. It >et out Henn weeeime omen» staitficatten, rend, at teecani Aldan II dientle 2 Tow impala sun be mend s eaten one before Not/ember /I /Old Peat note the tensed &elm kt pnnxled a mente teen biota CA Fonts." The and., need. 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Fagt 2 el 4 EACI4/455CAU3(11/8: Responses Hot Prefabs= Processaistase, oiCy' mar oe taxed to :One; ,88 11/8 Include a (No o: net A. Thee mad address may only be used Inc inquiries Do not send responses to t lw e mad address I 1290 AB Eatraord.nar. Ability in U✓Axis Lou MCI Akan) Muni 11C Well Fans 1 119 ketonic lux Kosamnagrani Worker welang 0 lB IwIanillitsfalA classilkanon lot lea. kw &oriel s1/4 an An Ilortnot I Talent Cuctriknaim Thee IB rlassilwaticri 'ors to individualswith extraordinary AIM, ar the atts The individual ns0,1 have stNainrd I.100I131 Cl unteinativr.al an Lunt Fin of Mt Oalle‘t FIX nit must le tr. Me held 01 expertise and 111O% a RCS 4.1 prcmir.rnte it luso: her held le. process your pennon and determine, d the benehrtaty n eggil.)e sithirOnn udurmatien is rectum! I his request pot ides suggested enders that sou nay submit to satisfy each tteueswel item You may Submit on, sone nr W W these einto Subunit IVO? Of IM SureArd items and tr.steail subnut other es-tele:re to saints ilr mcwse brine has IM evidence Jr Me word already muldnists Iter.uest a derma bawd on the word Am. ficnvever, Ilwl yost are resp3r.silele lot prOnellrges sle nee NA AtOAs dot siu Aral the mews to ilitsrtni....n nen al •rquereentnts bie:we must show chm all patens were apt* for the tegument lemon win. you l0nl Frnu I 149 Grand Requatinenh Inn MI 0 Vinanntigrant Petu:non h. oral pelneras vtlar.l: 0 noraninsTart t Mitch ton must treludt Copula( turbans A tineflints:not meronseunon4 mid [s: or perienflair ES and At lean or. To sang) thew requirements you submitted • lout teller lr. suppen ci the peation ant Pert Stool u. supra: n el net Intimacy hum CPAS AtANG oral Ala Ansamout benelic.n s 'Clem)°, 0 I Slalin Pennons Imes-ma; ar exiemmr.01Slaits fora henetwary pencuil) leen hat led 0 I ncnirmingiani AM", ono m IN en Earle store honAl r U I Cournslup Ana InalVaion Staves (MC'S/ nitlihOSIZed lc iloaillOr. emersion petionm Men a winternal oar m rirutnsnrxes Orton When rrievara Wit rhangt ISOM One pi, illion Po MAIM: CI Whril It. pale: spinosa! May last fern. lased ai on% LAOS am loO unhuk lNr ion !flirty LIT y was PriVitnAl, gianwl 0 I ominumgrasii sinus Alai your company The buds U. 6410 it litI• previous g-ayilosnirlil with you, Casspaliy lie Zr:: Ely( a:Arran/ na thr instant Irrlitoll A anew ol the mato- Ail/irateril sashrales nut tote %cube. st ul (11811.1Z/tiOf. his renamed tthrhAt.gfil Inc motors Foliliat may halt hear approsed In 11101 as Un of stain vair ptilorled tip ran appal IC &Anise a Foam 1797 01:03/90) Y Fl art oFFI: F IlS$ OXLY EFTA00599962 li S Drpartrr• m ol !Lamnami Seesaw L. I ()nieustny) and linnugrato:n Servo t s Nfft(t nt Aft: ; ŁAC la tz5St 803(l pastusio It the om It atldmon no erxlenrt has tren sularalled u sapam your claim Mal Mt her.ehriny tiar. Mdmdual LL he nas e suaordirmy, ahthry ul lu nas rku has Iren J.momsred by Lusaamell nit local or role rrlitonat at cl im Too haw caorumtrinl Me barer ir—ryi psu surrey w the bounty c( Miming and °manor. mailing abla re• kul Uus eolowe rotas lo the akr ty en Mr held ni Laury" cot Ur ins Thenlote you are Wail m mmiii* with the Wlew log Contra( Pettions Strklitg O acnimmostar I e Issuhrshot must whale a cipy ol s toast i bevveto the inebtaary Md Plitt the roniłom or the Yrnployer II s %Wien r untract dots Mr rxist sou nur 1111Chn J i iPisiN9I summary Li OW rms ol the trel. Ithseen itr beLthaary and either Iw perMOner or the entry< i sou dyl mit sul4mt M etyleny tot itr refy:Tr:um: You may siu submit miler."( to saltily n Winiet. COMMIS ci he MA ‚Mini 01 lir terms of m oral egret nora inuu %rafl Mr lenn% arat rorahoom of the rmyklmeLl uI vrvires T hry MUM Spnth Mr info Merril nil explam ten rims salin:Alton Val • r h It henrhetar, will redom Mer rental ani • fletni ary ohlttional voice% rovideil „MOP ni lir !rem or bawetami Sou miru rond, ar esplsnancr. of its romp tmor. nrn os prlormance to why h eV Ix-It...lyre> win paroapatt ar ever) trini alt Nlnin such s a sotralW pallet COLItlehle COMeithe.l. In Me ony" /c kie year os emagement donng cle requested valolos parad It tit vtipitor. soi( wlaniami o mmHg( itrt In year lane you lut tle duties Ol Me maned pour Kt t% tO tps)1111bIt łoi ortneettg the 111151w auras of the army (gave ten maga niuni at the maki. Inure% ads and in litu path host Coordmaw te purity; cl morals w rai pholopapbeti knit It trerkltitg Cl north 10 (brim Travel around Me matki to Ilnmser my talon sal to uss: łut v ph MC" Models and Fihnlih le Ishomlips with agea re% /WM..: IheMOIk) and nrislune I r inevniatich agar Moth It duties vat dew nic AKCJI W Iene fxClUtlys13 io itr mainimunt e Cl Ol a nalehhg /WW1 AN pressousty seated sou haw den unarr.led MIP Istr.efir , 'aryl psu „wrr" it korral r.,t; aid °periling mot Wag diffir !oxen IIIV,OldPrge putta lo Ikr li‚th ty tr. the fleki of IJIAUieli hours ani bonio mi Iroi dulek It tal it O W mnotntricrara clasvn nun vi appropriate tt itr ;miara ere Regulation% ikara ar 'aro' li W. held creative italSr, 01 rniesva such as hot roi kmin! W lur arts mad trIt t", Ms aril pawiom% alit A el 'gaged ar. lir held of ans IM lUll• WI t: LI% Ikr pnrottptl neuron eel prriomyra Ikr owi rveraul renom wis a hu: R i kminl kk Murton sil draguYiL hghlms; sleiagrors robed iinignns CholeOpaptirn ahdrOWgigS Ugaili lOn tin hrUlalull CO& hel Mitlogelf 11.11W1114pfITISOn COSIUTTI Form 1797 (8'03/90) Y Pak LiFilt USI t MY S MEGIEM ',/(gm•MM EFTA00599963 I I' Ik^pninw ril .,I poor pod Yri.111h Q end Irlintigrollun StrVit rs •M'ii/ft NArrmn ?grit d 4 MC l4 55‘1103g i designer. nukeup arrus the9i mayfly suge terhuaunt numil tritnen TA- dupes youth-scant cauesperai lo ',unrest aral maneenwra tut:owns not to a p3utten Mt am BrItut atudnanon N your petition car prormil this thurepar.ry mutt lw ttsolvrO You may gill wield .'nitrote an tangy Um requitement IM iletariptior mutt nxitnie An explanation el Ne natur, el the everts or it fisnlies Beginnr.gai4 enhy Oates of lit trtrils of an arid A ropy of any nu:nary that thmi dates ninth) ol ihr rmplopert nil rotation el Mr estio(s) Yeu nuMrSlibbth tat taw pt011eled pt9Mian qualdies as a pcuhor lc tin ant as 'kw oh& abort, Any and all dams mum I.e lutly tuppo:uil Iy Oofonlerltry Form 1797 (8/03/90) Y }t tit I l'Nt JNI EFTA00599964 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 Stales Citizenship& Immigration Services Vermont Service Center 75 Lawn Welden Street Saint Albans, VT 05479 R1 NO I LOCATION OF WMIDRAWAL OF 1.129 PETITION UTITIOUT PREJUDICE BY PETITIONER LAC-14-21540SO Petitioner: MC2 MODELS MIAMI LI.0 Beneficiary: JEAN LUC DIDIER HENRI RENE BRUNEI. Dear Sur Madam. Please be advised that this office represents the shove referenced petitioner and beneficiary in this immipanon matter and a 0.2R from our ofTice is on file. THE PETITIONER. MC2 MODELS MIAMI LLC HEREBY NOTIFIES L:SCIS THAT IT WISHES TO WITHDRAW I-I 29 0-I PETITION rtEAC-14-225-50X03. The petitioner requests withdrawal of this I-I29 petition without prejudice Please note this request fix the record in the above referenced case. We respectAilly request that you send us verification of this withdrawal pursuant to the regulations coniaints1 in X C.F.R. See. 103.2 0,105/. Kindly send our office a wntten vaitication of this withdrawal located at: tont Law Group. P.A. 3440 Hollywood Boulevard. Suite 415 Hollywood. FL 33021 Thank you lie your attention to this mater. EFTA00599965 -- 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 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 EFTA00599966 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 be in to repair your reputation. In the end I am afraid the damages are a lot more than you realize but keep fighting and moving forward as we have no choke. Thanks, Jeff Jeff Fuller President MC2 Model Management USA EXHIBIT K EFTA00599967 FROM: JACALTIE JOHNSON <.1.1O11NSONQIRRA-LA W.( 'OM> DATE: SEPTEMBER 18. 2009 3:37:44 PM EDT TO: ""l'ANIA@THI'DNIANLAW.CONI" CAMArlithl'ONIANLAW.COM> CC: "BRADLEY J. EDWARDS" <HEDWARDSaRRA-LAWst SUBJECT: EPSTEIN - DEPO OF JEAN LUC BRUHNEL We have confirmation for Mr. with you. Jacquie Johnson Legal Assistant to Brad Edwards. Esq. Partner Rothstein Rosenfeldt Adler 401 East Las 0las Blvd. Suite 1650 Fort Lauderdale, FL 33301 Telephone 954 315 7264 Fax 954 527 8663 Jiohnsonerra-law com deposition on 1113. We will commence at 10:00 a.m. it that is ok EXHIBIT I EFTA00599968 —Original Message— From: Tama Beth Kudman <[email protected]> Dale: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos are cancelled for now. A letter confining 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 EFTA00599969 From: "Dr. Royce Jalazo" <[email protected]> To: [email protected] Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this e it al notification that Mr. Jean Luc Brunel attending an outpatient individual 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. 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Its.4 wcYnm. y, ',II), • iesooti v41. ,ft PlOridkjah nits bass mends asOban to/ No Slime Anne« Frond, ~wind agency acreadda IM MC2 regency in .. ~te r 41Silionsonk.all-j.,le. ,4 tort•likerbeiw.11 • nOttatoleaCtr"..' yly EXHIBIT Q EFTA00599978 http://www.politien.com/blogs/under-the-radar/2014/12/court-filing-levels-sex-elaims-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 Bruncl'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 I8-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 EFTA00599979 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 ■. 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 inc 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 EFTA00599980 While "Jane Doc #3" is unidentified in this court filing, her story appears to track with that of a woman who stied Epstein in 2009 and settled with him later that year. She apparently granted an on-the-record interview to Daily 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 Spaccy. 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. I lowever, M. District Court Judge Keith Marra ruled last year that the victims arc entitled to examine those records to prepare their case against the government. Epstein, Black and others appealed that decision to the Atlanta-based I I th 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 EFTA00599981 ---- 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 Sechtoi Sent Thursday, January 15, 2015 5:12 PM To: Abi Schwinck Subject: Victoria Hey Abi! 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 %%. .natteparkesattencv.com The Page Parkes Building 1535 West Loop South, Suite 110 EXHIBIT I EFTA00599982 Houston. TX 77027 P: 713 807.8222 F: 713 807 0055 EXHIBIT I EFTA00599983