Filing II 17175578 Electronically Filed 08/15/2014 08:06:39 PM

Filing II 17175578 Electronically Filed 08/15/2014 08:06:39 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEI. Civil Action No.: Plaintiff, vs. TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. VERIFIED COMPLAINT FOR EOUITABI,E RELIEF AND DAMAGES COMES NOW the Plaintiff, Jean-Luc Brunel, by and through undersigned counsel, and sues Defendants Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for equitable relief and defamation, and states as follows: 1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County, and Plaintiff Jean-Luc Brunel resides in Dade County, Florida. 2. Florida Statute 48.193(1)(aX1) ("long-ann") authorizes service on both out-of-state Defendants. 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANTS 4. Plaintiff Jean-Luc Brunel ("Brunel") is the owner of a modeling agency known as "MC2 Model Management" ("MC2"). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 1 EFTA01107970 5. Defendant Tyler McDonald ("McDonald') is the owner/operator of Yi.Org and also does business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org"). Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service based in Vancouver, British Columbia, Canada. 6. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting websites that contained hyperlinks that contained blatantly false and extremely disparaging information about Brunel. (Exhibit attached). 7. These links clearly and falsely associated Brunel with illicit escort services in the state of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or should have known. was false. 8. 'Mese links have damaged Brunel's reputation as an owner of a well-established modeling agency with offices in New York and Miami, MC2 Models. 9. These links have also damaged the reputation of Brunel's modeling agency MC2. 10. The combined damage to the reputation to both Brunel and MC2 has resulted in a significant loss of revenue to MC2, and accordingly, to Brunel. 11. MC2's revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 12. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Brunei's reputation and directly caused damages to Brunel and MC2. 13. Brunel continues to own and operate MC2 Models to this day, his name still harmed by the false and negative association with escort services in Florida. 14. Accordingly, Brunel has been severely damaged by information on websites hosted by 2 EFTA01107971 Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 15. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiff's alleged involvement with escort services in the state of Florida. 16. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the name of Brunel with regard to the false and defamatory information disseminated by the websites they hosted. 17. Bninel continues to own and operate MC2 Models to this day, his name never having been cleared from the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald. 18. Brunel has been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and McDonald, and has accordingly retained undersigned counsel to represent him in this matter, and is obligated to pay counsel a reasonable fee for his services. COUNT I — EOUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE AGAINST MCDONALD AND MCDONAI,D D/B/A YLORG 19. The allegations contained in paragraphs 1 through 18 above are re-alleged and incorporated herein by reference. 20. Brunel, through his agency MC2, has lost a significant amount of business revenue because of the actions of Defendants McDonald d/b/a Yi.Org and McDonald set forth above. 21. Brunel has no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of both Defendants. 22. Accordingly, Brunel seeks to become whole by the payment of damages by both Defendants to compensate him for his losses. 3 EFTA01107972 WHEREFORE, PLAINTIFF requests judgment against DEFENDANTS as follows: A. I)amages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT II - DEFAMATION AGAINST PLAINTIFF BY MCDO NA LH AND MCDONALD D/B/A YLORC 23. The allegations contained in paragraphs I through 22 above are re-alleged and incorporated herein by reference. 24. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published, false statements about Brunel using their domain hosting service. 25. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the statements about Brunel were false. 26. These published statements were read by the internet users who viewed the false statements. 27. Plaintiff's business reputation was severely damaged as a result. WHEREFORE, PLAINTIFF requests judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT III - EQUITABLE, RELIEF FOR REPAIR OF BUSINESS REPUTATION 28. The allegations contained in paragraphs 1 through 27 above are re-alleged and incorporated herein by reference. 29. Brunel has also suffered a significant loss of his own business reputation and a loss of his agency MC2's business reputation as a direct result of the actions of Defendants McDonald d/b/a Yi.Org and McDonald. EFTA01107973 30. Brunel has no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business reputation due to the actions of both Defendants. 31. Accordingly, Bnmel seeks to restore his business reputation, and that of MC2, by the payment of damages by both Defendants to compensate him for his loss of reputation. WHEREFORE, PLAINTIFF requests judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. /s/ Joe Moue Joe Titone Attorney FL BAR #: 203882 621 S.E. 5th Street Pom ano Beach Florida 33060 EFTA01107974 VERIFICATION STATE OF FLORIDA COUNTY oW/Ase pdee JEAN-LUC BRUNEL, being duly sworn according to law, upon his oath, deposes and says: I have read the foregoing complaint and all the allegations contained the in. All such allegations are true based upon my personal knowledge, informatioq and belief. Sworn and subscribed to before me this day ofitide...il-r- 2014. MOO VALIMIAP111 II4try PO* • Ilal• el Ficekla * Cent helm 0441, 241$ Crate • U 271810 _19,21-tslmn't 6 e - NOTARY IC 6 EFTA01107975 4 Y. ih EA; .1,3;0 Atiwittittlmita ,r 1 , — ii.viL; ' '.• • crime( Joan-Luc Brunel, who co-owns the MC2 agency in Mlaml Beech. Ea0Ort end ?Ind %emit/hoes ensnared In e pelytorgiortando•flaida- <htip://poinciana-abo-sc8-ape.yi.org/odando•florida-> escort. is 'Florida' ,c994p6pisar'gicoldwup gid esocwt in flodda sites as reported by WWW. ... French modeling agency owner tAst• *Seel, vete co-owns the MC2 agency In ... eortyl.org/gIrl. <httplisunrisa-abc•ticeraps.yi.orgigd•>. escort-In-florida • %m / rail.110ach Visitirtg Escorts bike polies escort. Most radio stations drop Iglesias from . . French modeling agency owner whopo-owns the MC2 agency In Miami o sCoiermi.ythrgirnorth-miamlibeach-visiting•ascods •http://lhews-abc-sc6-tips.yl.orgInorth- C)riatting4corts> Sin star • j. ',45peti . ppcttsisi Mears legitimate professionals. French modeling agency owner Joairtua 02.42401§the1402' Oncy in MIan- Beach ... tikilictishb404ohYdeki i is- Ihttrilin-washbum.yi.orgirlavis-> oscortos/ - $imligr i • • ‘4tarrt • ihken-1, Prune': who co-owns the MC2 agency In Miami Basch. % co !0F l n Flendefarfort onienyLO libt4vOrtiontorle callfcmla hick- women yi mot> escortigirts.in itertdeesoens ter No Strings Attached ... French modeling agency the MC2 agency in ii• itflowyp-calligirls.y.orgimiami•baach florid*. encode/ bga . 7 EFTA01107976 • Re: Case number 14021348CA01 Dear Jean-Luc Brunel, In response to your affidavit, 3, m. - rrl yi.org is a domain hosting provider. yi.org does not produce any content of it's own, nig does it host any content. It only provides DNS lookup -- translating hostnames to P addresses. it is used for free DNS hosting by hobbyists, soccer teams, police stations, India musicians, and, unfortunately, sometimes abusive spammers and hackers. When a hacker or spammer is identified, their account is disabled and sometimes their information is forwarded to the authorities. Neither yi.org or Tyler MacDonald had any Involvement with the content that you found on google. Al that yi.org provided was the registration of the hostnames. For example, from your photo I can identify the hostname 'escorts-in-washbum.yi.orgi. The service yi.org provides, is to translate that to "66.71.253.78'. Nothing more. Therefore, I am unable to take the offensive content down. Al I can do Is turn off the abusive account, which I have done. However, if you go to http://66.71.253.78/ , you will still be connected to the offender's website (which appears to be fronted by a beading website). I can not turn that off. The only people who can turn that off are the person who put the content online, or the ISP that owns 66.71.253.78 (the WHOIS record for that IP has been attached to this letter for your convelnence). yi.org has been online for 15 years. in that time, I have taken down hundreds of abusive accounts upon request. I have checked my email archives, and you never sent me any notification of this abuse or request that these sites be taken down. If you had done so, you may have saved us a lot of trouble. This Is not content I put online. 47 U.S.C. § 230 (c) (1). I will be holding you responsible for any costs that I incur responding to your invalid claim. At the moment, that will Just be postage to reply to your claim, which I will bill to your lawyer. If you take it any further, you will be billed for time and inconvenience (both my lawyer's and mine), travel and lodging in Florida, etc as well. EFTA01107977 Here Is the Information that I have on the abusive account in question (the registrant of "escorts-In-washbum.yi.org"): Email address: gplithrmOstonallsam - Googie will provide law enforcement with this account's registered name, address, where they logged In from, etc.. with a warrant. Registered hostnames: 2,760 - This is an unusually high number. most of my users have less than 20 registered hostnames. IP Addresses: 33 - These are where the offender is hosting his or her content. Each of the 2,760 hostnames he or she registered maps back to one of these 33 IP addresses. I am disabling all hosts registered to the account l'dpkshrm4,[email protected] now. it may take up to 24 hours for the changes to take effect globally. If you have any other questions or concerns, let me know. Please confirm receipt of this message and your intentions with regards to this civil suit. Thanks, (Attached on following pages: List of IP addresses used by offending account, and WHOLS record for "escorts-in-washbum.yi.orn. EFTA01107978 Active IP's for this account as of September 17th, 2014, 3:36Phl Pacific: data 66.71.247.203 66.71.247.204 66.71.247.205 66.71.247.206 66.71.253.74 66.71.253.75 66.71.253.76 66.71.253.77 66.71.253.78 74.86.202.94 74.86.202.95 75.126.136.28 75.126.136.29 75.126.136.30 75.126.136.31 74.86.196.248 74.86.196.249 74.86.196.250 74.86.196.251 74.86.202.88 74.86.202.89 74.86.202.90 74.86.202.91 74.86.202.93 74.86.202.92 67.228.190.104 67.228.190.105 67.228.190.106 67.228.190.107 67.228.13.240 67.228.13.241 67.228.13.242 67.228.13.243 + + EFTA01107979 WHOIS record for 66.71.263.78 (IP for "escorte-In-washbum.yl.org"): f # AKIN WHOIS data and services are subject to the Terms of Use # available at: https://www.arin.net/whois_tou.html If you see inaccuracies in the results, please report at # http://www.arin.net/public/whoisinaccuracy/index.xhtml # The following results may also be obtained via: http://whois.arin.net/rest/nets;g=66.71.253.787showDetails=true&showA RIN=false&ext=netref2 NetRange: 66.71.240.0 - 66.71.255.255 CIDR: 66.71.240.0/20 OriginAS: AS14141 NetName: WIRESIX NetNandle: NET-66-71-240-0-1 Parent: NET-66-0-0-0-0 NetType: Direct Allocation Comment: WNO12-ARIN RegDate: 2008-01-24 Updated: 2012-03-02 Ref: http://whois.arin.net/rest/net/NET-66-71-240-0-1 OrgName: WireSix, Inc. Orgld: WIRES-2 Address: 55 Marietta Street SW Address: Suite 2100 City: Atlanta StateProv: GA PostalCode: 30303 Country: US RegDate: 2007-12-17 Updated: 2010-12-27 Ref: http://whois.arin.net/rest/org/WIRES-2 ReferralServer: rwhois://rwhois.wiresix.com:4321 EFTA01107980 OrgNOCHandle: WN012-ARIN OrgNOCName: WireSix Network Operations OrgNOCPhone: +1-678-525-7307 OrgNOCEmail: [email protected] OrgNOCRef: http://whois.arin.net/rest/poc/WNO12-ARIN OrgAbuseHandle: WN012-ARIN OrgAbuseName: WireSix Network Operations OrgAbusePhone: +1-678-525-7307 OrgAbuseEmail: [email protected] OrgAbuseRef: http://whois.arin.net/rest/poc/WNO12-ARIN OrgTechHandle: WNO12-ARIN OrgTechName: WireSix Network Operations OrgTechPhone: +1-678-525-7307 OrgTechEmail: [email protected] OrgTechRef: http://whois.arin.net/rest/poc/WNO12-ARIN RNOCHandle: WNO12-ARIN RNOCName: WireSix Network Operations RNOCPhone: +1-678-525-7307 RNOCEmail: [email protected] RNOCRef: http://whois.arin.net/rest/poc/WNO12-ARIN RTechHandle: RTechName: RTechPhone: RTechEmail: RTechRef: RAbuseHandle: RAbuseName: RAbusePhone: RAbuseEmail: RAbuseRef: WNO12-ARIN WireSix Network Operations +1-678-525-7307 [email protected] http://whois.arin.net/rest/poc/WN012-ARIN WNO12-ARIN WireSix Network Operations +1-678-525-7307 [email protected] http://whois.arin.net/rest/poc/WNO12-ARIN # ARIN WHOIS data and services are subject to the Terms of Use it available at: https://www.arin.net/whois_tou.html it I If you see inaccuracies in the results, please report at EFTA01107981 http://www.arin.net/public/whoisinaccuracy/indexachtml Found a referral to rwhois.wiresix.com:4321. %rwhois V-1.0,V-1.5:00090h:00 manage.my-tss.com (Ubersmith RWhols Server V-2.3.0) autharea..66.71.240.0/20 xautharea-,66.71.240.0/20 network:Class-Name:network network:Auth-Area: 66.71.240.0/20 network:ID:NET-6050.66.71.253.64/27 network:Network-Name:SECONDARY network:IP-Network:66.71.253.64/27 network:IP-Network-Block:66.71.253.64 - 66.71.253.95 network:Org-Name:EWDHosting.com network:Street-Address:34 Peachtree ST network:City:Atlanta network:State:GA network:Postal-Code:30303 network:Country-Code:US network:Tech-Contact:MAINT-6050.66.71.253.64/27 network:Created:20130314144920000 network:Updated:20140612131823000 network:Updated-By:[email protected] contact:POC-Name:Coloat NOC contact:POC-Email:[email protected] contact:POC-Phone:2399350520 contact:Tech-Name:Coloat NOC contact:Tech-Email:[email protected] contact:Tech-Phone:2399350520 contact:Abuse-Name:Coloat NOC contact:Abuse-Email:[email protected] %ok EFTA01107982 ----E Il IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL aRcurr IN AND FOR IRAMI-DADE COUNTY, FLORIDA. IN THE COUNTY COURT IN AND FOR SALAMI-DADE COUNTY, FLORIDA. DIVISION O CIVIL OTHER CIVIL ACTION SIMMONS (b) Form for Personal Service on a Natural Person CASE NUMBER 14021348CA01 PLAINTIFF(S) JEAN-LUC BRUNEI. VS. DEFENDANT(S) TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG CLOCK IN THE Ns STATE OF FLORIDA:TO EACH MIFF OF Ty£ STATE, YOU ARE CONSAM40CD lo serve Ifils Simmons one a copy of the Canfield SI tan eon deindent TO Tyler Didendwi(s): MCDoneld Address: 2708157th Avenue SE, Snohomish, WA 98290 NeCtilAtli A leveret has been Bed against you. You have 20 or/ Ida days after this summons b envied on you to Be a "e'en response to the Dawned corrnsdnt with the desk of this court A phone cal wIl not protect Ku Tar written response. Include:at the case nunber gMn above and the names of the patter mtat be SW If yew want he cart to hear your Ode of the case. If you do not ore your response on 0me, you may lose the case. and your wages, money and property may thereafter be taken without taller ww* tom the Court. There we Oater legs nX8granall. You may slot to owl an attorney right Sway. If you do not know an attorney, you may cal an attorney mien* sante or a legal ald oleos (Med In the prow Wok). if you chop,. to fle • warren response yourself, if the same time you Se your whin response with the Clerk of the Court, you must also mail or take a copy of written response to the ThentiftPtentlfhe Mornay rind below. The central lociellon of the Clerk's office le at me Dodo County . The address fix the courenee ard branch locedcos are listed beiow for yaw convenience: DARE COUNTY COURT LOCATIOSIII '..; • Oat Curb Carta (CM Room 133 73 W881 Pea snug ant Ralde 13180 MEN Inch GSM Carl (30 Recur 203 118)VArtiren Awn§ • • 22410 Caleb Cott am Room 103 5103 NW 22 Awns NS* FloMe 3314; Cal Oatio• 01•16,1Cast (73) Po:6103 31C0 Pore De tan Sat • • ?lot Cele as Cate( c2.3) Roca 103 12655 Men OM tort Matt llood1, $881de 33150 flom Cafe as Conte 121) Roca 1200 10710 WIN 211 VAN SERVICE a ori asst. Fiala 13130 cow as. NAM 33114 168* rung. 33118 0 testae mina an Rum 11:0 It 1.88106111n81 Hash. earn 33010 Mardil/Platrallf Attorney JOE TTTONE Florida Bar No. 203882 Address: 821 S.E. 5TH STREET, POMPANO BEACH, FL 33080 HARVEY RUM* BY: iiF,CTOR pupo DATE ON: CLERK OF COURTS DEPtiTY Pak WW1 % Ii ithsi AMERICANS WITH DISABILITIES ACT OF 1990 ADNOTICE • "If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the Eleventh JudicIal Circuit Court's MIA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1 Ave., Suite 2702 Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Far (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." CLK/C7. 070 Rev. It/11 Clerk's rob sakes& wortmlin1-026818rtcom EFTA01107983 *it** DUPLICATE Ok 4* 4* Clerk's Office: Miami Dade Counter Fl Entered: 8/26/2014 12:54 PM HOUPO Office: CIVN Batcht 159292 Trans: 4 Rot.: 3380005 Civil Circuit Fee Acctt 14021348CA01 3139 Summons Issue Fee $20.0C Check 4366 Ck Amount = $20.00 .1*-3EN DUPLICATE titen EFTA01107984 Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC Civil Action No.: 14-21348 CA 01 Plaintiffs, vs. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND DAMAGES COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami, LLC, by and through undersigned counsel, and sues Defendants Jeffrey Epstein, Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable relief and defamation, and states as follows: 1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County, Plaintiff Jean-Luc Brunel resides in Dade County, Florida, and Plaintiff MC2 Model & Talent Miami, LLC, has an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. 2. Florida Statute 48.193(1)(aXI) ("long-arm") authorizes service on both out-of-state Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org). 1 EFTA01107985 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jean-Luc Brunel is the owner of Plaintiff modeling agency known as "MC2 Model 8c Talent Miami" ("MC2"). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 5. Defendant Jeffrey Epstein ("Epstein") is a hedge-fund manager with a residence in Palm Beach County, Florida. Defendant has been the subject of significant media coverage due to charges brought against him involving sexual contact with minors. (Composite Exhibit A attached). 6. Plaintiff Brunel and Epstein have known one another since the inception of Plaintiff MC2. 7. Plaintiff Brunel operated his modeling agency, Plaintiff MC2, without incident until Epstein was first charged in Palm Beach County with unlawful sexual contact with a minor in 2006. He was convicted of soliciting prostitution from a minor and sentenced to eighteen months in prison, of which he served thirteen months. He remains a registered sex offender in Florida as of this day. 8. First, after the initial criminal charges against Epstein were filed in Palm Beach County, Plaintiffs were widely implicated in the media as being "linked" to Epstein. These false stories caused both Plaintiffs a tremendous loss of business. 9. Plaintiffs lost multiple contacts and business in the modeling business as a direct result of Epstein's illegal actions. For example, several photographers will not work with MC2 due to the 2 EFTA01107986 adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking Plaintiffs with those activities; namely, sex trafficking. (Composite Exhibit A). 10. One example of such a photographer was Michael Avedon, who worked with MC2 on photo shoots. Avedon stopped answering Plaintiffs' emails and phone calls after having known Plaintiff for some time. Upon meeting Avedon out one night, Avedon stated to Plaintiff Brunel he had "found out some information" from some friends of his and that he could not associate his name with MC2. II. This statement by Avedon was no doubt a reference to the alleged and false links between Plaintiffs and Epstein's illegal activities with under-aged girls. This incident clearly illustrates an example of lost business on Plaintiffs' behalf. 12. The second example of a business relationship that was terminated due to Epstein's intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos Model Agency. The owner stated that the model to be placed with MC2 "found some article in internet, which changed her position and she preferred to be placed with another agency." This was relayed to Plaintiff Brunel by e-mail dated October IS, 2014. This amply demonstrates that Epstein's intentional & illegal activities continue to cost Plaintiffs' business income. (Exhibit 13 attached). 13. A third example of a lost business relationship can be found in an e-mail dated October 17, 2014 (Exhibit C attached). The director of the 1 Mother Agency, Vladmir Yudashkin, states that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs' will force her into illegal activities. The model bases her fears upon the stories on the internet falsely implicating Plaintiffs as being involved with illegal activities with young models. This is 3 EFTA01107987 another example of a false link between Epstein and Plaintiffs, costing Plaintiffs' business income. 14. A fourth example of a lost business relationship can be found in a second e-mail dated October 17, 2014 (Exhibit D attached). Manucla Martinez of Mega Partners, a Brazilian modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs . This reference is clearly to the false allegations online regarding sex trafficking that were based in the false link between Epstein and Plaintiffs. 15. A fifth example of a lost business relationship can be found in an e-mail dated on Plaintiff's behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agencc France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of Epstein's illegal activities, Plaintiff Brunel was forced to forego (and lose) this business opportunity because he needed to keep a low-profile at this time. 16. A sixth example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail dated December 12, 2014. (Exhibit F attached). Michael Sanka, a talent scout who had worked with Plaintiffs for a number of years, informed Plaintiff Bninel that he cannot sign any new models for Plaintiff Brunet's MC2 agency due to the false sex trafficking allegations online. Sanka goes on to state that Plaintiff Brunel's MC2 agency will not attract any new models if Plaintiff Brunel does not clear up the false allegations. 17. A seventh example of lost business due to Epstein's intentional and illegal activities can be found in an e-mail from Fox Fashion Agency (Exhibit G attached). This e-mail clearly states 4 EFTA01107988 that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems. I thwever, because of the false Internet trafficking links between Plaintiffs and Epstein, Fox states that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up. 18. Before the false links between Plaintiff and Epstein surfaced, Plaintiff Brunel was earning a great deal of revenue from MC2 Miami. 19. The false links between Plaintiffs and Epstein began to surface online in about 2005- 2006. Then, in 2006, Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs then made an investment totaling one-million dollars with Elite Paris, to start a company. 20. Next, Plaintiff Brunel started the company, "E Management", to work with Elite Models in Paris, Plaintiff had to close it almost immediately, because Elite didn't send any models to Plaintiff MC2 for fear of being linked to Epstein. 21. Because the false links between Plaintiffs and Epstein began to gain strength online, Elite Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment of one-million dollars because of this loss of business. 22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar loss. 23. Additionally, a former financial controller of MC2, stated in a 2012 deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under- age model. (Exhibits HI & H2 -Transcript of Deposition of 24. was fired from her job at Plaintiff MC2 for embezzling company funds, and had criminal charges filed against her (Composite Exhibit I attached). She was also the source of the false information linking Plaintiffs to sex trafficking in the articles written by o f the website Jezebel (Composite Exhibit A, p.2-7). 5 EFTA01107989 25. The deposition testimony o referred to above clearly demonstrates that Plaintiff Brunel has clean hands and was never involved in sex trafficking. All of Plaintiffs' damages came solely from Epstein's conduct. 26. Additionally, Plaintiff Brunel has had significant delays in obtaining his visa to come to the U.S. These delays were also the result of the false link between Plaintiffs and Epstein. As a result of these delays, Plaintiffs lost a considerable amount of time & money. International travel is a significant component of Plaintiff Brunet's MC2 modeling business. Plaintiff Brunel has been forced to cancel his latest visa application as a result of the delays. (Exhibit J — Composite — Visa Does). 27. As a result of the notoriety and tremendous publicity surrounding Epstein's criminal charges, and the media linkage of Epstein to Plaintiffs regarding illegal activities, Plaintiffs lost a tremendous amount of business and revenue. 28. Plaintiff Brunel's agency MC2 has lost millions of dollars in revenue since the media revealed that Plaintiffs and Epstein were associated. In fact, Plaintiff MC2 was worth millions of dollars; now, due to the illegal actions of Epstein, MC2 is almost worthless. 29. At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the Epstein's illegal activities. 30. As a result of Epstein's illegal activities and his association with Plaintiffs, Plaintiffs continue to lose money and suffer damages to this day. (Exhibit K attached, Jeff Fuller email, 11-12-14). 31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to what it was once worth — money that the Plaintiff Brunel does not have. 6 EFTA01107990 32. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names never having been cleared from the massive and totally negative media coverage involving Epstein and his illegal activities. Plaintiffs have been, and continue to be, irreparably harmed by these false internet•based links to Epstein. (Exhibits R & S attached). 33. Second, Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Bruners deposition. 34. As a direct result of Plaintiff Bninefs travels, his deposition was delayed twice. When it was finally scheduled for November 2009, Plaintiff Bninel was in fact available (Exhibit I. attached). However, a medical emergency in the family of his attorney further delayed this deposition (Exhibit M attached). It was never rescheduled and he was never deposed. 35. This was a blatant example of obstruction 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 Bninel was under tremendous psychological pressure throughout this period of time. 37. This psychological pressure resulted in Plaintiff Bninel avoiding business contacts as set forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts during this period of time. 38. Plaintiff Brunel became extremely withdrawn and anxious at this time. 39. Epstein's conduct was the direct cause of Plaintiff Brunel's psychological state. The press was reporting extensively on the lurid details of Epstein's illegal activities with the under- aged girls. 7 EFTA01107991 40. As stated above, the press reports were erroneously connecting both Plaintiffs to Epstein's illegal activities. (Composite Exhibit A attached). 41. Epstein's illegal activities were outrageous and extreme; they involved receiving massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the girls with a finger or object; or full-intercourse. 42. These activities described above caused Plaintiff Brunel severe emotional distress. In fact, Plaintiff Brunel has recently undergone psychotherapy with a local psychologist, Dr. Royce N. Jalazo, as a result of Epstein's actions and the negative results on his business. (Exhibits N & O attached). 43. Plaintiff Brunel is emotionally destroyed as a result of Epstein's actions and the resultant effects on his business. He has been on medications to deal with the effects of this. (Composite Exhibit P — Medical History). 44. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counsel to represent him in this matter, and arc obligated to pay counsel a reasonable fee for his services. FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A VI.ORG 45. Defendant Tyler McDonald ("McDonald") is the owner/operator of Yi.Org and also does business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org"). Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service based in Vancouver, British Columbia, Canada. 46. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting websites that contained hyperlinks that contained blatantly false and extremely disparaging information about Plaintiffs. (Exhibit Q attached - hyperlink scrcenshot). 8 EFTA01107992 47. These links clearly and falsely associated Plaintiffs with illicit escort services in the state of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or should have known, was false. 48. 'These links have damaged Plaintiff Brunt's reputation as an owner of a well•established modeling agency with offices in New York and Miami, Plaintiff MC2. 49. These links have also damaged the reputation of both Plaintiffs. 50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss of revenue to Plaintiff MC2, and accordingly, to Plaintiff Brunel. 51. Plaintiff MC2's revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Plaintiffs' reputation and directly caused damages to Plaintiffs. 53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, both names still harmed by the false and negative association with escort services in Florida. 54. Accordingly, Plaintiffs have been severely damaged by information on wcbsitcs hosted by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 55. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged involvement with escort services in the state of Florida. 56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the names of Plaintiffs with regard to the false and defamatory information disseminated by the 9 EFTA01107993 websites they hosted. 57. Plaintiffs continue to do business to this day, their names never having been cleared from the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald. 58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and McDonald, and have accordingly retained undersigned counsel to represent him in this matter, and arc obligated to pay counsel a reasonable fee for his services. COUNT I — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANT JEFFREY EPSTEIN 59. The allegations contained in paragraphs I through 44 above arc re-alleged and incorporated herein by reference. 60. Plaintiffs have lost a significant amount of business revenue because of the actions of Defendant Epstein set forth above. 61. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of Defendant Epstein. 62. Accordingly, Plaintiffs seeks to become whole by the payment of damages by Defendant Epstein to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT II - OBSTRUCTION OF JUSTICE - EOUITY - AS TO DEFENDANT JEFFREY EPSTEIN 63. The allegations contained in paragraphs 1 through 44 above are re-alleged and incorporated herein by reference. 10 EFTA01107994 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 Plaintiffs 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 EPSTF,IN 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 EFTA01107995 COUNT IV - EOUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG 71. The allegations contained in paragraphs 1 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 EFTA01107996 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 - EOUITABLE 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 Joe Titone Attorney FL BAR #: 203882 621 S.E. 5th Street Porn n B a Florida 330 13 EFTA01107997 VERIFICATION STATE OF FLORIDA COUNTY OFiliaAr/ oaf JEAN-LUC BRUNEL, being duly sworn goading to law, upon his oath, deposes and says: I have read the foregoing complaint and all the allegations contained theogin. All such allegations are true based upon my personal knowledge, inforoutiog and belief. Sworn and suttecribed to before me this / day ofzreme_a-r- , 2014. MAO VALLADAM Ilan it • hit el Moss WPICaritlapfrooOdlIMII Comelse • RIM% kell'istlik•41.1O••• - - - - NOTARY UBLIC 6 14 EFTA01107998