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

fal IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA. Ej IN THE COUNTY COURT IN AND FOR MINALTIADF COUNTY. FLORIDA 0 CIVIL U DISTRICTS O OTHER CIVIL ACTION SUMMONS (b) Fenn for Personal Service on a Natural Person CASE 11.113EP 1402134ISCAO PLAINTIFFS) JEAN-LUC BRUNEI. VS. DEFENDANT(S) JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A YI.ORG CLOCK W THE STATE OF FLORIDA:TO EACH SHERIFF OF TIE STATE, YOU ARE COMMANDED to sane EH Sinn* ameaboley of lie COmfialal this tarrHill on dated:tat In To Ostandangsy j JEFFREY EPSTEIN El Addrale: eqe, le ef. O, .• EW-ike 4-z 3n1-4/ 351 Billie Way Palm Beach, 33410-4 0 Siaret # !vti II41-stigia Aorta mmerreza A Iowa* has been Ned no a.lretl You. 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The address for the courthouse, and taiinthkCaticts are Wed brew for your carnelian®: CADE COUNTY COURT LOCATIONS tie )Nen on also is G Garb Coates P:61 O.1•••••• Caleb CS (301 0 0100 Oody mom cams Int SERVICE Roes 733 WS 103 Rem 100 73 wee P)Ja Sari 3030 KW 22 Maw liSSS Biscayne 8hd• — finch El x How. nos 33142 1400 aim nuke. FloOlb 11103 0 Men we, Dana Can al) 0 Gni GS awe Can DS) 0 11070 ems raw cow cm Item Ho a oen KO Rags IMO t13011/711,0,7/CA •WFJ• 3103 WO a Ise en 10710 86, 211 Sari Yon awn .svm. The Caw GS RIMS 33134 10a F 33103 0 IMMO CS (21) Room 100 11 NU Sin Dna Mai* Floe 3:Will PNInellFlaintiff Mornay JOE TROVE Florida Bar No. 203882 Address: 621 S.E. 5TH STREET. POMPANO BEACH. FL 33060 HARVEY RIMH limn ISAING1-1Et : DATE Ott ELS 0 9 CLERK OF COURTS DEPUTY CLERK 20 15 AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who _needs any accommodation t inro:fsgern participate in this _proceeding, you are entitled, at no cost. to you,_ o_ the p _. certain assistance. Please contact the Eleventh Judicial Circuit ADA Come& Lawson E. • house W 1 2, Miami, FL 23128, to p lator, Telephone TDD Fax at least 7 days before your schedu e sou • ppearance, or MON a ely upon receiv ng time before the scheduled appearance is less than 7 days; if you impaired, call 711." his notification are hearing or if the voice CM= 070 Nee Wit OelesesbakInet wwsw EFTA01122242 O EN LA CORTE DE CIRCUITO DEL UNDECIMO CIRCUITO JU DICIAL EN Y PARA EL CONDADO DE MIAMI-GADE LA FLORIDA 0 EN EL TRIBUNAL DEL CONDADO EN 'e' PARA CL CONDADO MLAMI-DADE. LA FLORIDA DIVENON 0 CIVIL OMA EMPlAZAMIENTO DE ACCION CML (b) NOT1FICACION PERSONAL 01 PERSONA NATURAL DEMANDANTE(S) VS. DEMANDADO(S) NUMERO DE CAS° HORA Dernendado(s): MPORTANTE Usted ha We dernandsde leipanenie Tune 20 dat cortedei e ~ir del recto de Ma ~adert para ~Ms, Ia domande ~Na. Por °solo. y Pnaerda da arde egt inbula. Urm boude Weerga ne b protegera. Si ~d desee qua el ~d armere su *Se Proscillar su resFuesru por ett. Iltl.~0 el menen> del ~yin nomhzes do Lis Ine iremealas. SI tatud no ~tem Ie tienpo. miese poon. el casu poid na eer deepclodo de sus Ingre505 ypinpiedellea. 0 ~0 de sus derediee, sn previo aviso del beaat Existen ceres itquisee legalas. Si lo des. wede IS consult/ratel ebewelo inneceatamenie SI ro ~stat Myriade puede knar • una de les ollände de aseiontia koel (Lagal AM Olfloe)oun segbecio de reforencle de abogadoe (Attomey Referte! Servan que warmen en Is etria lekNonea. SI dan ~ander a ie ~anda ps sti ast, al M25000 tkártp0 *fl quo ~Sta Su ~at& mto el eiburial, debeire talud envár pp ~en o enlrepar en e mano tra copla de su raspuesla a ia persona denornineda ab* wee lalainerePlantiffs Allerner (DemardanleoAbcgsao del Dall0000100) y 07170.30017 w catetesan a u ~ende al Sealt:b del Jwyado. La utikacloo coca do la Mina dei Sároraeb este en el «sado de la CtrIe del eend/do de Dode. La direaion de la Code. y de las cacursales maan on ia boa aglienoi punt au comeniencir : LOCAUDAD Ce LOS TIOBIUNMES Dfl COMIADO DE DADE O oen Cal, Caárli~ (05) D ~Mi Ca Ce 1301 n ~h 0a Jas ~er (231 IJ ~am aai 01) Roos 133 Ros 103 ~n KW Roem 130 73 Va nat Ser 140/ 71 Aam 15555 Raiyee 0553 ll EER) én 31-).. Mna 71orkie 30130 syn-.bs 33142 ah Mom lbootn nes. 3.11110 R10•••• 11oRs 'nr." K 1.1.19 ~ei 00•n C.« ra) Gas 0~3 w1 osi LT st.n. mara Cali. (201 Ra 300 Rea Im Ns 1303 1130~ Raa0 310) Parie Oe la *cl 36/10 Sr 211 Sta ~I `d l Rondo 333» Cad CableR ~de 33114 Mia R1/4043 33110 Detnandenle oAtopedo Od Damandante Direccion: Numero del Cdegio de Abogados: EL ESTADO DE LA FLORIDA: A eada Sad! del Estado: Se le ordena que hagen entrega de esta notficacion y u ta ode de le deinende an •10 piib el 71015017~9(7) 771~015057 ambo HARVEY RUVIN Secretarie del Tribunal del POR: Condado COMO Beenden° Adninlo Ley para Estadounidenses con Incapacidades "Si usted es una persona inhausválida que necesita hater arreglos para poler partcipar en este proceso, usted tiene derecho, san gasto alguno, a que se le provea cierta ayuda. Por favor péingase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial ubica-do en el Lawson urtho NW 2702, Miami Fl 33128, Teléfonos TDD Fax por lo mens 7 dias antes de la a ga a para su comparecencia en los r una e_; anmediatamente después de recibir esta notificacién si el tiempo antes dc la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitación del &do ode la voz, !lamt al 711." FECHA CUUCT D70 Rei 11111 ClerVe Wr adthrse we nam dadel( dorn EFTA01122243 0 AU TRIBUNAL DU ONEEME ARRONDIE:MENT JUDICIARE DANS ET POUR ISAMIOADE FLORIDE. O AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE TENA-DADE FLORIDE DIVISION 0 CIVILE 0 AUTRE PLAINTE(S) A (AUX) ACCUSE(S) CONVOCARION D I ACTION CIVILE (b) LIVRAI ON PERSONNELLE A UNE PERSONNE NUMERO DE CAS VS. CONTRE ACCUSE(S) HEURE IN ADRESSE: IMPORTANT poursuites Manu ont ate enterprises œntru aura. vous errez 20 fours coraeorots a parer a de ka dire de rassIgration de ale Cabal pour deposes une response ease a ta pro (Seine aptes de ce Mine Un secte coup de teleçœne est nellisant pour vous prenez Vous ewe oasis de depose batte anise talle, nec menin du numem de douer *dessus el du nom des battes noroises id. si vous souhaitez que in tribal enterait von Causa Si as ne agate pas este repense ecrite dans In Mi nette van natta de perdre YI couse muez que sen salaire votre arpent et vos ben pomma en usa pas la sa, axai primats ullenaur do niai. Il y a daubes obligations juridiques et vous pouvez roquet Ws satins iniffellatc d'un avocat. Si voie ne connaissez pas dace. voue pOumez lekephOrM a un .avive relatante cavala ou a th butas dam:stance )aequo (Routard a tarnualte de teuton«) Si sa Cheistssez de demis« ww-rnewa ive none, calte. d va faudra egalesnert, en ment bimps que celte formate, faim pans nit ou axpedIer une copie de von aorte esta au liamtlf/Plaines Attorney (Plaignant w a sen avocat) narine ciMeSSOU5 et IMegere votre reportes awe b Cirta du Tribunal. L'adresse watt du bureau du Greffer est Io Dada County Couilhouse. L'adresse du tharseet redresse des succursales sent *ana ci-dessous parr sotte oonvenen ADRESSES DES tRIOUNAUXrN da O DIS Cam, Cavons, 105) G Man Cab Canar (20) n Mod. or s, Canar an ( ) >luis nia isq Room 134 Mes 103 ROM in ROM 100 r3 rem ftegbe use sue W. 22 rate ISSU encaver end. ln tionniMSWM sud. now Un» sur MM 3:1142 /Me mmo Mum Ç 2310 mise. flmedn 3301s D MM "mn outil Can IN) D Cal Gia tau Gail QS) Li tan osa Jante cana da) mas MI Men Mi Mon tac II» Welmen Musa 3100 Porto of Lim ami 10110 St ill Sr 'MM Osa Flonda nia Cal OS VIMY MU Morat Mens MIS Plainte/Avocat du Plainte Humer° de bureau de la Ronde: LIAT OE LA FLORIDE A chaque te il de refait vota etes otage de presenter cette citation et une photocpie de la plaines te ce document SW recouse (e) a-destes. Adresse. HARVEY FtliVIN Greffier do Tribunal PAR: COIME GIEFFER ALUttaT DATE ON: ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE I' ADA "Si vous êtes une personne handicapée qui a besoin d'accommodement pour pouvoir participer à cette procédure, vous avez le droit, sans aucun coût, d'avoir de l'aide à votre disposition. S'il vous plaît contacter le Coordinateur de FADA du Tribunal de l'Onzième Circuit Judiciaire, Lawson Eassak6sithottse W 1" 02, Miami, FL 33128, Téléphone I ffl ; TDD Fax au moins 7 jours avant la date de comparution au tribunal, onbien immédiatement après avoir reçu cet avis si la date avant la comparution est moins de 7 jours; si vous avtz une incapacité pour entendre ou parler, appelez le 711." OMET. 07o Rev (lilt dort% webinlabanc wimMninidedeSrli.Con EFTA01122244 0 NAN TRIBUNAL OfIZYEM ANNONDISMAN .11DISIE NMI E POU kausoAnc COUNI Y, FLORIDA 0 NAN TRINNALEPOU TRIBINAL NAN MIAMI-DADE COUNIY, FLORIDA DNIZYON U SML 0 LOT PLENTIF(S) KONVOKASYON POU KA SML (b) OEUVRE PERSONELAIAN BAY YON NOUN VS. KONT AKIZE(S) NIMEWO KA AtOZE: ADRES: LE Yo entre yon aksyon kont oumeum. Ou genyen 20 jou kalandnye apres ou recevoi somasyon-an pou enregistre c ovan grebe tribunal-sa, yon reponse pa eat attache nee plent-la. Yon apal pa teletan ka kapab prolege-ou. Se yon repents pa alto ou ma numem ka-a ki sou let pagela avec nom rurune-yo ki sou papie-sa oblige esi si ou vle ke IribunaHa !Bade position-au cou ka-a. SI ou pa enregistre noponotfrou a Mauro ou capab pedu ka-a san tribunal le pa anounce-ou or' yen, ou capab pedu ragen 01/ Mc byen ou. Genyen lot demands. Ou ka besoin !arena yon avoka tout de suit. Si Ou pa Conan yon awl's. ou ka role sate kl ntkonsaride evoke, ou dro edit legal (kJ nen le liv talons). Si ou shots/ voye yon memos pa ecsi oumenm, ou supose On mem tan poste en men, tan posts on pole on copi response pa sal pou evoke ',Sayan ou pleyan-yo ke norNi ama-a et enregistre reponee-la nan tribunal-la kl localize nan svek Shkrete Tribinal. Adres amber biwo Secrete a se Dade County Courthouse. Adres biblical le, ak rakes lot Iribinal yo nan lis ki r nba a pou ou ka peen yo titer. ADRES TRIBBIN. NAN DADE COUVRY 13 Nat cane ~Ms K6I 0 Wok CS Whor We) 0 tens ors AS Cs Oh Roos 133 Res 103 Woo 103 73 WS Hagler SI SOO) NW 12 Sown 13063 Nrilymt ONO IS Row. Sitt WM. WS 33742 NoW Mood Ow" RS WOO a wr WO. Mon Cowl 00 0 OW Oaem Oln Cool (15) 0 3M, INW WOW WIN 001 RS 200 Rs 100 ROOM IWO 11)3 WiNwiton Nwew 3103~ Os Is *is •0710 W 211 Wm my., flwm 331M OW OS. 7~ 33134 YmN Pae.ctu WOO LI Sires moat PO Room KO II Emi MYam ISO. F-11010 PlainlalAvocel du Plainte Nina de barreau do la Florida ETA FLORIDA: POO Chair nan eta s yo odane ou pau bay aka a (yo), gala anwo a. manda sa a ak yon kepi yo pate nan pease as a. HARVEY RUVIN ni L y: ~rate Jean) TrIblnal La "" LWA 1990 POU AMERIKEN KI ENFIM ANONS POU AMERIKEN Kl ENFIM "Si ou se yon moun lei enlim e ou bezwen akomodasyon pou ou patisipe nan pwosedi sa a, ou gen dwa pou yo ba on kilt ed san ou pa gen pou ou peye. Silvouple kontakte Kowådinate ADA pou Tribinal Onzyem Distrik Jidisye a nan: Lawson E bous W ågamsigja.2702, Miami, Fl 33128, Telefon TOD Fax =0~ omwen 7 jou enven ou gen randsva I pou ou paret nan tribunal la, oubyen Imedyatman le ou resew/a notifilcasyon sa a si o t gen mwens ke 7 jou pou ou paret nan tribunal la; si on gen difikilte pou on rande ot byen 11 pale, rele 711." Nimes*, minim evoke a. Address: DATE: SEKRETE CUf/CT 070 New IVII nemt'* ort0 soldreno wow many OaoWer‘ com EFTA01122245 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). EFTA01122246 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 EFTA01122247 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 EFTA01122248 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 Plaintiffs behalf was an e-mail dated August 27, 2010 from 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 EFTA01122249 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 EFTA01122250 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 U.S. These delays were also the result of the false link between Plaintiffs and Epstein. As a result of these delays. Plaintiffs lost a considerable amount of time & money. International travel is a significant component of Plaintiff Brunel's MC2 modeling business. Plaintiff Brunel has been forced to cancel his latest visa application as a result of the delays. (Exhibit J — Composite — Visa 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 EFTA01122251 32. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names never having been cleared from the massive and totally negative media coverage involving Epstein and his illegal activities. Plaintiffs have been, and continue to be. irreparably harmed by these false internet-based links to Epstein. (Exhibits R & S attached). 33. Second. Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Brunel's deposition. 34. As a direct result of Plaintiff Brunel's travels, his deposition was delayed twice. When it was finally scheduled for November 2009. Plaintiff Brunel was in fact available (Exhibit L attached). However, a medical emergency in the family of his attorney further delayed this deposition (Exhibit M attached). It was never rescheduled and he was never deposed. 35. This was a blatant example of obstruction of justice in the criminal case. Epstein was solely responsible for telling Plaintiff Brunel to leave the area. Plaintiff Brunel lost a huge opportunity to clear his name, and that of his agency. Plaintiff MC2. 36. Third. as a result of all of the facts stated above. Plaintiff Brunel was under tremendous psychological pressure throughout this period of time. 37. This psychological pressure resulted in Plaintiff Brunel avoiding business contacts as set forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts during this period of time. 38. Plaintiff Brunel became extremely withdrawn and anxious at this time. 39. Epstein's conduct was the direct cause of Plaintiff Brunel's psychological state. The press was reporting extensively on the lurid details of Epstein's illegal activities with the under- aged girls. 7 EFTA01122252 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 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 EFTA01122253 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 Brunel's reputation as an owner of a well-established modeling agency with offices in New York and Miami, Plaintiff MC2. 49. These links have also damaged the reputation of both Plaintiffs. 50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss of revenue to Plaintiff MC2, and accordingly. to Plaintiff Brunel. 51. Plaintiff MC2's revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Plaintiffs' reputation and directly caused damages to Plaintiffs. 53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day. both names still harmed by the false and negative association with escort services in Florida. 54. Accordingly, Plaintiffs have been severely damaged by information on websites hosted by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 55. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged involvement with escort services in the 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 EFTA01122254 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 EFTA01122255 64. Plaintiff was forced to commit illegal acts by traveling away from the sight of the deposition and during the time period of the deposition. 65. Defendant Epstein attempted to subvert justice and this attempt contributed to the destruction of Plaintiff's business, Plaintiff MC2. Plaintiff Brunel lost substantial time away from his business and incurred expenses in following Epstein's commands. 66. Plaintiffs were substantially damaged as a direct result of Epstein's actions. WHEREFORE. PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT III — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 67. The allegations contained in paragraphs I through 44 above are re-alleged and incorporated herein by reference. 68. Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by engaging in illegal conduct with under-aged girls, which was falsely linked to Plaintiffs. 69. This illegal conduct was extreme and outrageous by any standard. 70. This extreme and outrageous conduct was the direct cause of extreme emotional distress in Plaintiff Brunel. WHEREFORE, PLAINTIFF BRUNEL requests judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate II EFTA01122256 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 EFTA01122257 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 S.E. 51h Street Pompano Beach. Florida 33060 13 EFTA01122258 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 EFTA01122259 COMPOSITE EXHIBIT A 15 EFTA01122260 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 EFTA01122261 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." 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 EFTA01122262 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 Epstcin'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 EFTA01122263 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. Epstein also enlisted his staff in the predatory activity, and fou Lesley Groff, and efigured 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. lie 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 EFTA01122264 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 52,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters such who brought them to the house. He also testified that Epstein made large contributions to the Palm Beach Police Department, and in return was given PBPD baseball hats to put on the dashboard of his various cars to avoid being stopped or ticketed by local police. Retired Police Chief Michael Reiter, in his own deposition, acknowledged that, in addition to earlier donations to the police department (which are fairly common in well-heeled Palm Beach), Epstein had recently given the department $100,000 for some sophisticated equipment. The police were still researching the purchase when Epstein came under suspicion, and Reiter ordered the money returned. (Guy Frostin, one of Epstein's local attorneys, told police that Epstein also gave $100.000 to the Florida Ballet for massages, because he was "very passionate" about massages being "therapeutically and spiritually" beneficial. Yet victims told police they had no massage training.) Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel. owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell. Brunel, Rodriguez, and "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 EFTA01122265 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 EFTA01122266 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, [assistant 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: bu in a 14- ear-old Yugloslavian named Natalia- 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 EFTA01122267 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 EFTA01122268 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 EFTA01122269 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 EFTA01122270 "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 EFTA01122271 http://www.huffingtonpost.com/conchita-s-sarnoff/child-traffieking_h_1269748.html 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. 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 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 EFTA01122272 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 EFTA01122273 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: bum a 14- ear-old Yugloslavian named Natalia - from her parents in order to keep as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economicallydesperate 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, assistant 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 EFTA01122274 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 EFTA01122275 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-appeals- court/ 31 EFTA01122276 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 EFTA01122277 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, who's currently a partner in MC2, denied allegations in a 1997 "60 Minutes" segment that he took advantage of young models who were high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2. says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 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 EFTA01122278 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 EFTA01122279 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. Clint ve s planes, many times with Maxwell, Palm Beach resident and ' - "all employees and/or co-conspirators of Epstein's,'" according to the court papers. The documents show that Clinton flew with Epstein. "then suddenly stopped — raising the suspicion that the friendship abruptly ended ... "Epstein's personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him ... and what appears to be Clinton's personal numbers," the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards' client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time. 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 EFTA01122280 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 EFTA01122281 glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight. reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking 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. Brunei'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 EFTA01122282 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. Mode!. Michael Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger." says Jerome Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he's cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter. talked to the Wall Street 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 EFTA01122283 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 EFTA01122284 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, glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society. and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don't drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout" warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business. modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as "models." Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges 40 EFTA01122285 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 Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. "Jean-Luc is considered a danger," says Jerome 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 EFTA01122286 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 EFTA01122287 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 who's agreed to plead guilty to soliciting underaged hookers and go away for 18 months, doesn't want to be branded a "sex offender" for life. Page Six says his lawyers are thinking about asking prosecutors to drop that requirement from his plea agreement In a letter drafted, but not sent, to U.S. Attorney Alexander Costa and obtained by Page Six, Epstein's lawyer, Gerald Lefcourt, writes, "Doing so will have a profound impact [on Epstein] both immediately and forever after. Not only will he be restricted to a wholly inappropriate penal facility, but he will be required for the rest of his life to account for his whereabouts." Meanwhile, over the weekend Page Six said that owners of MC2 modeling, run by Jean-Luc Brunel — who's also been accused of favoring underaged models in the past — claim that Epstein is not the secret deep pockets behind the firm, no matter what others say or speculate. 43 EFTA01122288 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 EFTA01122289 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 Ilth Circuit ruled that discovery can move forward in an important Crime Victims' Rights Act case that my co-counsel, Brad Edwards. and I are pursuing. The narrow issue before the court was whether prosecutors and defense attorneys could assert some sort of "privilege' to prevent crime victims from reviewing the correspondence that lead to a plea bargain. More broadly, the ruling means that the victims will have a chance to return to the district court and seek to invalidate a plea agreement that (we alleged) was consummated in violation of their rights. I hope that the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach. I lere arc the important facts, taken from the 1Ith Circuit's opinion: The case arose in 2006, the FBI began investigating allegations that wealthy investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The U.S. Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution. and the FBI issued victim notification letters to my two clients. minors Jane 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 EFTA01122290 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 women qualified as "crime victims" under the CVRA. The district court later rejected the government's argument that the act only applies after the filing of a federal criminal indictment. (I've written a law review article about the issue of how early crime victims' rights attach in the criminal process. which can be downloaded here.) Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims' rights. To make the case for such a remedy, we moved for discovery of the correspondence between the U.S. and Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 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 remeds under the act. The court then ruled that we were entitled to review the correspondence, rejecting all of Epstein's arguments. On Friday. the 11th Circuit affirmed the district court's ruling, that we could rev iths 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 EFTA01122291 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 benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 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 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violated their rights under the Act. Moving forward, this case raises the important issue of what kinds of remedies are available for violations of the Crime Victims' Rights Act. Our complaint alleges that, prodded by Epstein. the federal prosecutors deliberately concealed the sweetheart plea deal they had reached with him to avoid public criticism of the deal. I am hopeful that in future district court proceedings. we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure. and crime victims' rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Utah. he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C. Circuit and for Chief Justice Warren Burger of the Supreme Court. an Associate Deputy Attorney General with the U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S. District Court Judge for the District of Utah in 2002.1n 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 EFTA01122292 ----- 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 EFTA01122293 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 EFTA01122294 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 InterneMari Relations Phone: Direct: Cell.: megatnodelbrasil.com.br EXHIBIT D EFTA01122295 Original Message---- From: Lorraine < Organization: MC2 MM Reply-To: Date: Frida Au ust 27, 2010 at 8:49 PM To: < , Jean Luc Brunel c: >, Pink Subject: FW: Press In ui from AFP (Agence France Presse) Videographer- >----Original Message >From: [maitto:[email protected]] >Sent: Friday, Au ust 27, 2010 11:03 AM >To: >Subject: Press Inquiry from AFP (Agence France Presse) >Videographer >My name is 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 re ards, j>= im EXHIBIT E EFTA01122296 >www.youtube.com/AFP >Agence France-Presse is the world's oldest newswire with journalists in >165 >countries. We publish worldwide in English, French, Spanish, German, >Portuguese and Arabic. AFP delivers the news to thousands of media outlets >worldwide from newspapers to magazines, radio and TV stations and online >services. It reaches an audience of more than one billion people daily. >This e-mail, and any file transmitted with it, is confidential and >intended >solely for the use of the individual or entity to whom it is addressed. If >you have received this email in error, please contact the sender and >delete >the email from your system. If you are not the named addressee you should >not disseminate, distribute or copy this email. >For more information on Agence France-Presse, please visit our web site at >http://www.afp.com EXHIBIT E EFTA01122297 Sept 4.0q, Sacretro Yob* — Original message — From: Michael Sanka Date: 12/12/2014 12:48 (GMT-05:00) To: Jean Luc Brunel Subject: Scouting Jean Luc, How are you? After so many years scouting for you and having a great network of agencies all around the world who enjoy to work with us, i wanted to let you know that we are on the way to lose everything we build and we are gonna have big problem now. Agencies, still want to work with us but parents don't want their daughters to come to us, because when they google your name and the agency name the only things they see is "Sex Trafficking"!!! It's impossible to sign a new girl and if nothing it's done i can tell you that in 3 months we we will not get any new girls and i don't see how the agency will work without new faces. All the agencies who know you don't have any problems with you since they all told me 'We know Jean Luc for more than 20 years and all those years we had so many girls place with him who had better experience than in any other agencies who were representing them as well and we never had any problems whatsoever, all our girls had great carriers as a model when he represented them". I understand those agencies because it's hard for them to talk to parents and explain that it's not the truth when it's al over the internet. You need to have it stop and have the people write an official letter to say that its not the truth... I will keep you posted of course but it's really bad for us and the scouting. Best regards EXHIBIT F EFTA01122298 FOX Attn: Scouting division MC? We took notes of your comments and the girls that you like WI our wehsitc. 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. AU the girls he represented from us nesa had any problems. they were working has great book work with gad clients in editorial and campaigns and were well represented models. Now for all the new faces we have, me 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 SCN [rollicking they were scared and l was myself speechless since we know that it's not true but it was hard for us to explain to the parents. So of course for the moment till all is clarified we can't place any new faces with you because the parents will refuse and it makes us look had to propose the girls to your agency. We are sorry but you really need to clarify es cry thing. till then we will hale to cease any collaboration and we will have to refuse to let you represent any of our models Sure you understand Sandra Petkanic Fox Fashion Agency Beograd t ice°. Swetaporµa 7s v stool? iroisisThsoglot it EXHIBIT G wt 1a EFTA01122299 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 that's 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, " look what just happened to me", that, 21 "something bad happened to me". 22 A Maybe a model came and told me, 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 EFTA01122300 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 EFTA01122301 COMPOSITE EXHIBIT ! EFTA01122302 V ill ta I tikart. ktu, Va t".n. Nrcndini IN Ire lit( i i i «,t kr ti/ nu tit% 'NUM t‘t.( IR< ill 't•D 111N t111‘11.1),N (bi (DI \I1, 11 O4t11) i f I axt ••••• Hr - [kn:: ..... As‘ngt r PLI %GREL MI.N1 < ()MIN Ni" li: %ni ritiNF rkR•Vtilir7 RItiDLF, %Ja .tikrtit, d tbc 11•-•<nti latt r,I • 1 i i. YL h a.hl Uka. *Øk thi ~7~1 1.w11Y 'slak %Vi gine•. Ma'n d'o: i "It. n• .1, . ••••• ▪ nal th. 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'Me/ el!! 1 istil i„ .•1: is.Pas I •.< A. / •ii '3 ri r T -- g • 153:19.2t %IL') • 4 L• • • • ,•pu 1 • em • • 2.; • :•• • • _ • • • I .art 4 LZiv t. •••• •••% I. • • LIT: ;is • ?— / I 9, 7 is. i) ;54 " PC.;•;" :C • g /VC 24/t VZ:i 11 17 if ..‘k•• n..; •IL -4 .• P Jr r v . 44n.o Jr h... .1: 11°P-12—ittireL.., itettat±..• j ‘ _Lejtal : .n..i r • I in IISLI k g ' Cjt elf t".ec:: ea../ f •1 • sv, A •Atte./c, • • '4./••••• i's• • .... .,. P 441 10. AV 1 r •••• l• .•.‘ S. •/ •• •) • 41\ d 4: •,•• r. • 5. rit r1., .1 t •. : •••••A • - 4-a . 1. .1 .tf. • • fr s • EXHIBIT I EFTA01122310 COMPOSITE EXHIBIT J - VISA EFTA01122311 8-79•711. Not... or Acne., at. a *2•11S' IR 8i'MC. • roe' Mi •. 1 . 1C ?Y. Iii Irli. MO Manic WIC ▪ I • • -•• r • • •••••rmer • • r • 4011 `17;017.sra—.72 .. Tit' PIPI•pr pep •-•-• TIE MP ••••• _,..... wm.s Coo •••••• P .•••••:9'-""' "Nr.a..44ITI-0..0"1"n . Pea PPP /C770 leper Pad P•Plaa/ eles • • • n ..iinererip Man INVIeelll ate ilpvl A. Pirelli I. Min r= ei-riarr — . Cita. • Waneadai Ipod• • lapeeelia V.f ILA *Me C••••.••••••b••••• fl are M d i • N i a t i pie W. 40 ••••• Sam, ••••• Am../ - ••••• • &a.m. US mob. in. wily %A.* • nap •••aar.••• rim wee •• ~a *rows nra.1 •=4= = • ••• .• •••• • •••••••••••• r =_...._ •• :te • - _ • - • " - a . • - • - • • _ ^ • - r at, Calsra rlEIPM min --." neap% " ‘006) •.-ratim.uas An. nammunu Th. Male de. !MM. •••• @Emma mills PIPPO dm • ...omen ••••••••.da •• r..r •• •••//lisa•. allin.•••• ••••••• •••• :ix -- . ▪ ipli *se ~ea •iman eeeee ••••••••• • . .. "MS I Pea Mee LOIN EFTA01122312 SUPPORTING oocumktos EXHIBIT 1 Several press and media articles documenting the nse of South Beach as one of the united Slates' main fashion copilots EXHIBIT 2 Press articles regarding the models and actresses who were both discovered by and coieeis were launched by the bens hoary Jean Luc Brunei. EXHIBIT 3 Several articles regarding the prestigious reputation of Konn Models as formerly one of the world s leading agencies. EXHIBIT 4 A Est of all of MC2's clients including several hgh•prolae campaigns featuring some of MC2's loshion models as well as several press clippings regarding this prestigious and reputable modeling agency. EXHIBIT 5 The tienehccary's. Jean Luc Brunel. impressive cumculum vitae. %replying his Iremencloin aCCompliShrnentf n both the fashion and modeing indusIzes. EXHIBIT 6 Seven]; articles rega•atng the 2O04 mocree New Generation Contest (including hanslation0 os well as the beneficiary's leading role within Ihrs prestigious modeling event EXHIBIT 7 Several press oilicles regarding the prestigious 2006 Models New Generation Competition lincludng translanonsl as wel as the benetcialy's Jean Luc Brunel. leading role within Mc event EXHIBIT 8 Letter of Claudia Midcro. President of Mocletwork. a renowned modeling agency EXHIBIT 9 Leiter of Alio Aimantovo. Director at Figaro international Management EXHIBIT 10 Several press articles reflect NI the prestige apa high circulation roles at the mentioned magazines and periodicals which have featured and covered the modeling events which the bevetiCt3tY Jean Luc Brunel. hos organized throughout the yeCal EXHIBIT 11 IntetniatiOn regarding the extremely successful and prestigious modeling and fashion association International Model Talent Association (IMTAI EFTA01122313 m c2 MODELS MIAMI July 25. 2014 Deportment of Homeland Security tinned Stales Citizenship a•td immigration Services Vermont Service Center 30 Houghton Street Saint Moons. VT 05478 RE: 1.129, Petition for o Nonimmigrant Worker O-1 Extraordinary AWRY as an Art Director and Talent Coordinator Petaionec MC2 Models Miami, LLC Beneficiary Jean-Luc Didier Henri-Rene BRUNEL Dear Se / Madam. The present teller and its enclosures ore submitted in support of the attached O-I petition of MC2 Models Miami. LLC, on behalf of Mr. Jean luc Brunel. The petition is based upon Mr. Brunei's standing as on "Alien of Extraordinary Ability in All Direction and Talent Coordination " Kindly note that Mr. Brunel currently holds O-1 status with our ofganizatIon. The South Florida area and Miami Beach in pOrliCulor hove become a mecca lot the fasnion and modeling industries. As a result. many of the 42irgest international modeling agencies such as Ford. Elite and MC2 have opened apices in South Beach and the area has become one of the most important in the modeing industry In foci, Miami Beach hos become second only lc 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 capitols. In 1996. our company MC2 (formerly Karin Models!. established on office in the heart of the historic MI Deco District of Mann Beach. -South Beach' hOs truly become one of the world's modeling copilots and we are pleased to tie a dot of it Our agency has developed a highly distinguished reputation in the modeling .ndustry We spnCialize in representing numerous mode:, of international acclaim. Hosting dacovered faces such as Chnsty Tudington. and mottled the careers of celebrities such os Sharon Stone. Esieua waxen. srtBa mil inuchh, man, • 1674 anon load • Mule 500 • 'mar", WC" 0 A3139 305672 R300 • his • admiroihalma 30S G 727672 • to 305 072 63.%• mt2mm EFTA01122314 Jovovich. Jerry Hall and Rebecca Ramp who is currently stoning in the award- winning ABC television senel. Ugly Betty: MC2 models ate among the most sought after in the industry. os evidenced by the caber of thew commeraol and editorial Coatings. Many of our fashion models hove graced the pages of reading fashion magasines of the United Slates. Etsape. Latin America. Africa. and Australia such os vogue. Teen vogue. Eøe. VV. Glamour. V. Morse Claire Surface and Cosmopolitan os wet as many more throughout the world. In oddilion to our Miami Beech office. MC2 Models hos Offices in New York City and Tel Avrv. Israel. As Artistic Director and Talent Coordinator to MC2 Models Miami. LLC. Mr Brunei will be resat:iota& for overseeing the artistic aspects of the agency By overseeing the art department ri the agency. Brune svl direct Ilse visual marketing cl the models to clients. focusing on the images placed on both the model's composite cards and thew portfolios Both of these marketing tools are crucal in marketing fashion models to their appropriate catalog editorial. a media clients. As Artistic Directed' and latent Coordinator Mr. Brunel wd also ,:oorchnote the paring of fashion models with a particular photographer. Cents for the agency valuate a myriad of fashion pubtcations. retail stare, consume product companies. ond loshior houses to name but o few Recruitment of talented artistic photographers who have on exceilent understanding at the -ins ond ails` of the modeing and fashion industry is CIACCe to the successful running of o top modeling agency such as MO Models Mt Brunei innu alto continue with he amazing tract record of discovering the weed's greatest talents and beauhes in order to sign them with MC2 Models. Mir Brunel win continue fn navel around the wØ looking for new talents. and to agencies around the wand in Order to establish relationships with those agencies and cep* MC2 Models Miami LLC to represent them in the United States Mr eivners impressive nualicalions as on Art Director and Talent Coordinator. establish eligibility as to the regulatory standards for such clossification as a top prolehioncii in tis field ror Brunet meets the O-I criteno as an individual cl execxxdriory ability in the Arts and Entertainment field os well as a business entrepreneur MC? Models Miami. LC is presently seeking rophateated art director ond talent coordinator After reviewing his experience ond accolades, we ore confident that the beneficiary. Mr Jean Luc Brunei we perform said nine non with outstanding skil ond professionalism 1, MR. BRUNEL'S QUALIFICATIONS AS THE BENEFICIARY in addition fc Jeon Luc Brunes extensive business Quokkahorn. his career as an individucit with artistic vision ono creative totems clucdities tin os on O.1 osen in the Arts ono Entertonment FØ His Olt- encompassing experience os an Art Director. talent Coate4notor international entreprene‘r and business EFTA01122315 'ender in the modeling. fashion, entertainment pubic relations. restouonl and toonsm industries hos made Mr Brune' infemolior.c.11y renowned in those lieds. Among his various occomplishmentS 'Nix/ghoul his career ore the successful modeling agencies he has founded both in Europe and in the Wiled 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. Brunei success was so great with Karin Pons that in the next ten years. he founded Next Model Management in los Angeles. California in 1980. Next Model Management in /mom,. Ficxrdo in 1982. Model Management Group also in Miami, cicada in 1986. and Rebecca Commercial Casting in New York City. in 1988 The latter one was opened as o talent and casting agency for performers. offering services such os voice-avers television and cinema advertising work. again. successful.), carving oul o niche by which to make his mark and achieve bold commercial performance results. Although Mr. Brunel later sold his rights to Next Management to Faith Kates n 1989, who partnered with Joel Wilkenteld 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. Do/stela Peslova. Audrey Quack Yamio Oct and Molgosio Bela. NEXT continues to mointain on cifluential international force in the fashion and modeling industry through its fully operaonol offices in New York. los Angeles. Miami Sco Poole. Montreal, lot dor. aria Pars os well as ifs affiliates in Won and Australia. Because of strong revenue growth and successful business performance as a result of his artistic vision os on artistic director and talent coordinator. Mr. Brunel founded the very successful Karin Models of Arnett° in New York City and Kann Models USA in Miami Beach. Mr. Brunet's COmmerciol ventures in opening Karin agencies in Pars. New York. and Miami hove been extremely successful generating combined annuct revenues of twenty five (25) million dollars. Eventually. Mr Brunet licensed the Kann name to agencies In Israel Cenma•k. Germany. and Sporn. Mr. Brunet's extroOranory talents are not only limited to tOunching suCCeSSIut modeling businesses. but o.so n discovenng and launchi-ig the careers of some of the world's most successful models Mr. Brunel has launched the extremely successful careers of supermOdels such as Christy listington Rachel Hunter. Sharon Slone Monica Beivcc. Estella Warren. and Christi ia Serronnovskoya These women all proceeded to become some of the most photographed international covet modes in the world. appearing on thousands of magazine covers wortchsnde and spanning many years Asa restot of his reputation as a highly viStie. strategic netwotker whc cultivates and conducts buttress in a ilobol environment and brokers lucrative cools. many EFTA01122316 lop players in the fashion and entertainment field requested 'hot Mr. Brunel function as their exclusive agent and representative. Some of these top former ancl pteseril professional supermodels in the fashion field include. Naomi Campbell. Christy Turlington. Rebecca Romiin. Milo Jovanovich, Inez Sastre. Melanie Them,. and Jerry Holt Attached as EXHIBIT 2. please find press articles regoiding the models and actresses who were both discovered by and careers were launched by the beneficiary. Jean luc Brunel. Additionally, attached os EXHIBIT 3, please find several reticles regarding the prestigious reputation of Kenn Models as formerly one of the world's leading agencies. Most recently in October 2005. and after his reign with Konn Models, M'. Brunel launched the prestigious MC2 Model Management worldwide with offices in New Yak, Miami and Tel Aviv Mr Brunel slatted the high profile MC2 Model Management in order to represent high fashion models in a boutique agency setting MC2 Model Management is comedy being lauded by !ashlar insiders as "one of the hottest agencies in North America" as weS as "prominently positioned to be one of the major players of the Zeros because of its insider relationships with the most influential photographers around.- We invite you to visit www.mc.2MM.c0m in order to view the high-Cofiber of models. MC2 represents Some of its most recent succesSfLi bookings include Uu Dan', exclusive contract as the face of the Fall 2007 Guess Campaign and Sammy Jots cover story lot Cosmopolitan Magazine. Attached as EXHIBIT 4, please find o fist of atl of MC2's clients. including several high•profiie Comp:signs fealising some of MC2's fashion models as well as several press clippings regarding this prestigious and reputable modeling agency. Jean Luc Brunet's entrepreneurial spiral is nol only contained to ire field at arts. beauty. and tension. In '970 as a result of his business insight Mr. Brunei founded and grew Jeon Luc Relations Publique. which specialized in press and promotions for tour operators and restaurants in France. During his work through Jean Luc Relation. Public:Tue. Mr. Brunel represented various key orients and collaborated on numerous prestigious events Some of the prestigious events include. Air Tour and Dora Voyages. Jean Luc Relations Publique also promotes and marketed La four D'Argent a Ihree-stor restaurant owned by Claude Terrell and. "The Go-Between", a motion picture by George Losey. Other projects token on by Mr. Brunet through his public relations company was hs work as product agent lor ;ear Claude Kitty. 1968 Winter Olympic Gold Medalist skier. to promote Vac. Colorado in Trance for tourism potential and also drected ak of the promotion fa finlard's ministry of tourism. In '975 Mr. Brur el lurthei ,nvested in the Food and Hospital'', market by creating and developing El Mono Desnuati"• a leger dory high-end bet on the iberian Peninsula. This bar was known throughout the peninsula as extremely exclusive and attracted a celebrity clientele the. included actress. Ursula Andress. and the Duchess D'Alba Attached us EXHIBIT 5. please find file beneficiary ' s. Jean Luc Intel. EFTA01122317 impressive cynics/um vitae verifying his tremendoth accomplishments in bolt the fashion and modeling industries. 11. Euoigiure FOR CLASSIFICATION AS AN ALIEN Of EXTRAORDINARY ABILITY IN JHE ARTS Under the Miscellaneous and Tecnnical Immigration and Nationality Amendments of 1991, petitions for clossiticalion os an Alien of Extroordinnry Abilily in the Ms must be supported by evidence of "dislinction". According to 8 CFR §214.2lcq pHs). "dislinction" means a high level of achievement in the field of arts as evidenced by a degree of skill and recognition substantially above that ordinarily encountered to the extend thial a person described as prominent is renowned, leading, or well-known in the fields of arts. This evidence may consist O prool Riot the alien must be recogdzed as being prominent in his field of endeavor as demonstrated by the following according to 8 CFR §214.2(0)(3)(ivi• A. Evidence that the alien has been nominated for or has been the recipient of significant national or international awards or prizes In the particular field such as an Academy Award, an Emmy. a Grammy. or a Director's Guild Award, or 6. At least three of the following forms of documentation: (1) Evidence that the alien has performed, and will perform. services as a lead or starring participant In productions or events, which have a distinguished reputation os evidenced by critical reviews. advertisements. pubicity releases, pubilcations contracts, or endorsements; (2) Evidence that the alien has achieved national or International recognition for achievements evidenced by critical reviews or other published materials by or about the Individual In major newspapers. trade journals, magazines. or other publications; (3) Evidence that the often has performed, and will perform, in a lead, starring, or critical role for organtzcrtiorn and establishments that hove a distinguished reputation evidenced by articles In newspapers, trade Journals, publications, or tesNmonlols; (4) Evidence that the alien has a record of major commercial or critically acclaimed successes as evidenced by such Indicators os line, rating, standing In the Reid, box office receipts, motion picture or television ratings, and other occupational achievements reported In trade journots. EFTA01122318 major newspapers, or other publications; (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 engoged. Such testimonials must be In a form. which clearly Indicates the author's authority, expertise, and knowledge of the alien's achievements; or (6) Evidence that the alien has either commanded a high salary or will command a high salary or other substantial remuneration for services In relation to others in the field, as evidenced by contracts or other reliable evidence; or C. If the criteria In paragraph (o)(3)(Iv) of this section do not readily apply to the beneficiary's occupation, the petitioner may submit comparable evidence In order to establish the beneficiary's eligibility. EVIDENCE THAT THE BENEFICIARY MEETS AT LEAST THREE Of THE PRONGS OF THE CRITERIA UNDER SUBSECTION The (list scoria that the beneficiary satisfies is § CFR 4214.21oX31(lyXliin I. which requires evidence that the alien hos performed, and will perform, services as o lead or stoning participant In productions or events which hove a distinguished reputation as evidenced by critical reviews. advertisements, publicity releases, publication controch, or endorsements. AS o result of Mr. Brunei's combined expertise in fashion aria tourism. he decided to creole Latin Model Pageants. now known as Models New Generation to cross promote these key industries with international business and investment opportunities. Mr. Brunel hos promoted and 'edged various modeling contests throughout South Americo including modering contests staged Fel countries such as Peru. Ecuador. Brazil, Argentina, and Chile Conceived in 1987 Inc Latin Model of the World event was a high-end modeling and entertainment product that appeared lo upscale internaliond audiences reacting nearly 400. million television viewers worldwide Throughout his history as a major intemoliono. event promoter and artistic and talent coodinotor Mr Brunel has orchestrated rnuili.faceted pubic relations. advertising and media campaigns that incorporated heevisson. magazines. programs. newsletters. and promotions. becoming notabty lucrative for venous molar brands as a promotional tool At Bruisers cm ute knowledge cyl marketing aria promoting wits hos turned his venous international events into highly successful artistic and busmess ventures lor various major brands Latin Model Pageants attracted major brands as EFTA01122319 sponsors such as American Amines. Roy-Bon. Coco Cob. Proctor d Gomb:e. and Revlon. Mr. Brunets has continued his ventures as both o aomoter and panel cadge when he founded and created the international modeling contest, Models New Generation that look place b Guayaquil. Ecuador in 2004 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 America. Asia. and Europe Alter ten days of harsh competition. Jean Luc Brunel crowned the winner. Alyne weber. o fifteen yea old from Brad. whom as a result of coming in hot dare 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 fa 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 grebe. the entire Association of Television Channel in Ecuador. Notional Television of China and Rede Gleba Brad's largest and most popular television network. Attached as EXHIBIT 6 please find several articles regarding the 2004 Models New Generation Contest as wet: as the beneficiary's leading role within this presrgious modeling event As a result of the tremendous success of the frost Modes New Generation that rook place in Guayaquil. Ecuador in 2004. Mr. Brunel organized the second model New Generation Contest which was held in 2C06 in the Ecuadorian coot! al Quito. In ode• to select only the very best new models several Preliminary qualifying shows were held in different countries of Latin AmetiCO inducing Bolino. Panama and Peru The lino! contest was held ,n Quito. Ecuador al the historicui Plaza San Francisco. Mr Brunel sat on a panel with three other PlateSsionah in the fashion industry and paged over forty-eight young women from twenty-eohl ditlerent countries horn North and South America. APO and Europe. After ten days of harsh competition. Jean Luc Brunel crowned the winner. Gob Lapina. or eighteen yecr-ola from Latvia whom as a result of coming in first place was awarded over three hundrea thousand dollars worth or niocieling contracts The city or Quito. Ecuador was also ttvnwn into the witernationat spotlight as the nost city for the modeling contest. Again just like the immense medic, exposure given In the first Models New Generator competition of 2004 the 2006 Models New Generation competition was broadcast cm numerous lelevis.On network channels including. Fashion TV, which trarisnwts to over 202 different countries throughout the globe. the entre Associarcri of Television Channel, in Ecuador National Television of Chino and Rede Global. Brazil ia•gest arid most popular tesewsbn network. Attached as EXHIBIT 7 please find several tress articles regarding the prestigious 2006 Models Nevi Generation EFTA01122320 Competition its wel as the beneficicuy's Jean tuc Brunel. leading rote within the event The 2006 Models New Generation program was broadcast in over 202 counties throughout the wok'. Mt Brunel has pertained and will most definitely continue $0 perform services as a leading parlcipant In mode erg events which have a chstinguished reputation and will bnng more pubbc international light to iAC2 Models For the above-mentioned reasons. Mr Brunel safeties INA §214.2(a)(3) (8)(1). The second atone that the beneficiary satisfies a ILSIE fal4.2(0k3Hlv)(6)(2). 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 lndMduol In major newspapers, trade journals. magazines, Or other publications Mr Brunel hc4ch an international reputation as a visible. shafegic network& who is able to cutlivate expert relationship management PSIS in order to conduct business in a global environment and broker luctotive deals. Mr. Brunel has a long hetory in marketing and advertising motor fashion campaigns Throughout he twenty-Rve year career in the fashion business. Mr. Brunel has developed woilawbe exclusive modeling and cosmetic campaigns. Some of mese major cosmetic campaign.) include: Bro Therm with supermOdet Fee mcPhersor. PHAS with Rebecca Bonen Christian Dot with Chnstino Sernonnorskaya. Margret Astor with Monica Bellucci. Chanel with Patricia Von Rickenhelm. Angel Perfume with Piety Mvgler, and Cacharei Perfume won Aida Ballesfra Mr. Brunet has also developed motor fashion campaigns and has developed campaigns and exclusive contracts with some of the weld's top faster:in designers such as Yves Saint lament. Chanel Chnshan Dor. Gucci. Praia and Mac Jacobs Please see the enclosed letter of Claudio Midolo. President o' Moctehvori a renowned modeling agency EXHIBR 8 As a talent coordinator. Mr Brunei's success can and should also be measurea with Ine istccessful careers the models. whose careen he launched have achieved As slated above. Mr Brunel has discovered and represented various super models throughout his career. Christy Turtington. who wa. discovered by Mi Brunel. has personified unaffected beauty- representing Colvin Klein's traganCes since 1887 Tueington. as well as another model represented b', Mr Bruner. Naomi Campbell, became' one of the Few soPermadeli, who managed to make on easy tranSitron From the haute (Osmotic O1 Iht 1980'S to the relaxed simplicity of the following decade Throughout he, extensive cateet. and Os a reSuil ut Mr Brunets ithhioti• Savvy Eye". Christy Tuningtor Lai graced the cover of hundreds of lathier, magazines such as COSMODobra., W Vogue, Shape Fitness. He. bazaar. mane Clore. Hofor's. EFTA01122321 Esquire. and even Time magazine Please see the enclosed letter of Allo Armontovo. Director of Figaro International Management EXHIBIT 9. In oddiron, the modeling events that Mr. Brunel has been organizing throughout the years receive not only national. bur also international attention and appear in multiple publications around the walla 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 mutilate newspapers and magazines. among them Globe Television Networks in Brazil. Fashion IV which is broadcast into 202 countries throughout the woad El Universe. CosoS. Lo Rozon Et [Norio. El relegrafa. Nomode. Extra Hoy. El Gran Gvoyoquil. Et Comercio. Semen. and 8 Lideres to name a few. these major publications hove a large subscription rote which numbers in the many miRiOns of readers. Attached os EXHIBR 10. please find Several DIMS articles reflecting the prestige arid high circulation rotes of the above-mentioned magazines and penOdicols which have featured and covered the modeling events in which the beneficiary, Jean Luc Brunel. has organ zed throughout the years. Hence the beneficiary satisfies INA §214 2(011310YME11(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 atom !hal the beneficiary satisfies is 6 CfR (214.2f0A3lovX0HC which requires evidence that the aBen hos a record of major commercial or critically acclaimed successes as evidenced by such Indicators as title, rating. standing in the field. box office receipts, motion picture or television ratings, and other occupational achievements reported in trade journals, major newspapers, or other publications One ol the ma:n reasons that Mr Brunet has been able to not only survive. but also be extremely successful in the ever-changing wand at fashion is his ability to identify and recruit stor-quahly talent. As o result of his ob:hfy to scos.,1 major talents. Mr. Brunel was invited to become a member in one of the fashion industry's most elite and important associations. the International Model totem Association (hereinafter IMTA) the IMTA is an international association of Ironing centers for models and Icrent. IMTA gives aspiring models actors, singers. and dancers spectacular oppoitunilies le 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 works Several of todoYs up and corning actors and models bore been discovered at EFTA01122322 IMTA. some of these discoveries include world-renowned arras such as. Eljoh Woods. Ashton Kutcher Katie Holmes. Eva Longono. Jessica Bret. and Sean William Scott Attached as EXHIBIT 11. please find information iegarding the extremely successful and prestigious modeling and fashion association. IMTA. Additionally. Please find several pages ham IMTA's official websife documenting their discovery of the Oboveimerhoned A-list actors and actresses, whose membership in IMTA proved to be the launching pad la 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 Irve [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 hove achieved a similar standing and hove been able la maintain it for over twenty-five years. For the above-mentioned reasons. Mr. Brunel satisfies [NA §214.2(o)(3)livilBI(4). VIDENCE THAT THE BENEFICIARY MEETS 8 CFR 5214.21O11310vlig The petitioner has submitted a plethora of evidence regarding Mr Brunel s experience in the fashion modeling industry. Mr. &unel's has established MC2 models, formedy Konn Models. which is presently one of the motor international modeling agencies. with combined annual revenues of twenty Sire million dollars. Only someone with Mr Brunet's expertise and strong strive for 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 tor the launch of numerous Supermodels' Careers. which hove been mointa.red the spotlight tor several yearS. He has womed with renowned fashion designers and phologropheis, who hove trusted his work and intuition in addition, Mr Brunel hos orchestrated many international and rational SucCesslul fashion events !hut hove iece.wed international OCCIamOliOn For the above-mentioned reasons Mr Brunel in addition to meeting at least three of the criteria of 8 CFR §214 2fOll3nv)(B) he also qualifies under 8 OR §214 2(O)(3)(iv)(C) III, CONCLUSION If is clear from the evidence lhot Mr Brunel is eligible for CIOSSifiCaliOn as an Alert of Exhoordinc.vy Ability in Arl Orect on and Toler! Coordnotion based EFTA01122323 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. EFTA01122324 Milan. spools It. 704 L•3O3 venue* Senn Castor 75 Low Weida:item st. a wn VT Otira-OO0/ Pt 0-t Vis Males no behalf d Jean Lae ISM Ment$4.4aw Unmet %.tite fhb inter In wn.o hurrovri o4 Mr Jan Ls Umndl applitg:on for a noz-Immigrant Ms to ibis mown, I am currently ittnnalnimratore Unit» In Studio P. I have been aged to review the peer sionat credentials4MA Brunei. add iv my pnefrazion.il optniop that Its broad • an Art Thiste set 'Zahn: Coordinator extrilthiinary thity wbo rank•smonx thr .mallpen't•tint et fist* Pc* M lay d kle Mild I haw awe Arq•bad Mr At laat's tpeecil expertise in tit Md. including =gift Pueduction. coodinittina. and an dirertion kr boom Mr Brunel It oun,klerni by those in (1111 kooky to be an extrao-dinar) creative director talent. partwolath for 9:. kebob and 'rived im.i.tnn In my personal dealings with Mr. Jon Inc Brunel I found llinb to thorough') piofasional and capable of bring viand in ratunt1114, wit► a wide range of met* 9ubjett saner co am. areginient. He bas Mr intuitive ability to provide joie ncedtd bt ansIlion nth any partrculat erealre proceas and cosset-sus excellod atthaa niazientenitd and operational sidga that come from his gran of experience. Many people do not understand that behind met aticcussful udvettid-gi camp. o and fashion shoot there are creative torn and Wall • ho are making sore that the hotness operates rffickraly by roordiuming different tasks between models, photogriplien, and mannpni *Stns teams. I can ')=nasty* that Mr. Bract consuaD lumseil tv. at tztrwardinart tart to V field. Witt an unmitigated rodonenient for Mr. Jean Mir Brunei raga niina eta Aga application as a person of extraordinary nhility Tbrre M OD doubt m my mind visit Ma popularity and Mabry in the field inn tank antimir to pryelsrr In span tr. come I • t • / • stilt... .;••••• .fir. Im es •+a EFTA01122325 ML al r Ve kretom on t...i:Vtd asr ...te »ner olsz Ina San I Glit ett Mer .n Mm k.q..port at W Jas fleunrbi :pigx.ajzon it.7 a r n attivarr alla lo an canantri ' an CIIIMM0 auealna u b Mant d Twa billanfarell sn iA ilielslea nara urea a wandzia la Sa areent GW" Star I Ma Itiquently tan 10 halma , IM andareak •I frtcvc.natt en the Sid I laniLa Me is tataar that ptaannti crednattal• .. Mr. k .år, la ZWM It M a PISSuclud ~im lama opon. too paria wal preasal labooloddat d W Bruneta tanta. thai W /Ma a ao avl ~w ol r•tredinsy akie S3O MIMO ang Ih^ inneti ~Wam at kar proleaccala at sn topola teti. I WWW adr Jean La Dunat and 'tet pkasurt b mu nb • Mad maro tian w ar high proIle ren ea e( the etapinin sak stach ht ellgalc- , tbdoltaane set the r ter eho aompiestaiee hm Wam Na ruckla: hatt uppetat ta m of W warld• mat rimte putikateene what littrolty te,thone ar adata tir theatotart Smog tar Hm nit M lo thirn tablett nu rj ond nilowi stot ha uprali:dom to aug• detali tud •• Odda Kitla. aut Chd•U•-• .hat ItYt • • hon a IM ladena hIC11 alm art darachtni ~bm tdd •• dr ay. Mm Ler ?MM m tbc coneamm pnakiselonal ohm it sa lo Iw an al tudam vd te «dt 8. 190 tutraaoa UN ~ 41 a au ettien A eva mun hr te e mmmii trd Y 11t• amellar hon d ar dant on non omem Nthwitt th enat , hi-ntonteht ar ben atapinedin kir heim ~rh. M ub md worth ua dei dba Lat arantl %kalana:fnalla‚ a. ta:04.0U S Ment I mm haltu. ennr., aosmatcarol adeime and KkaOVYOL.n.rn ~MI you luns e n...nstann • Kd ~ta eat nordman Mm, as :CKI ta s ozetatt nsa ISY Sr ya artflum ara reneadrratton EFTA01122326 0 PLEIMADWITUDIDS so oar Ind am na, n.a leet t Mae Ida 1411.1~~1121/011Ls Ierteretter.**4 Ur/ BS 0-11~grertVarettice oe Shed of roe Lae Bran Deft ot Sedge! Ilde letter is ~item to support raa aWILcatioc of .kan lu< Ikuhet to that he ratty be ~led O Ctnordflany Chitty Wit watt= to continue to atriums! O;ot11>F larlisbdy Øcdioj Ma« wear.ida tatidon frolitstrt, lairs reerarket >Loner at Gag Ånd &Wks, and bay nad anti, ant, ditch, as %nit I aka. Nu rofro. tolervinv, Voids Orrenatt /rely* and Abhor Joe Ire Iron hew bees inervetoteb nil con m atr 561 a nrsane who erW *at* rtaaw art direct faeleion nth* far dialer, p! view-AI:ern. eat Wt. Miao bat ■ utad e). to wiser the moo apprapriatr rocactela to be toted to or. atheataan ~1st and suks•qtx-r-thy hae the outztaadins ability Ul moray- all Stara et rhe ~plea pdottla nf parthertne the right rent In? 4 joh. That-fort, flt• quaitty ri bh -mkt., :or itttåttle a• he la ebbs to find the nxen baulk' toads. Pa a result he fit tag beccotnt one of the: profaeston la of choice for the haloon itclkattry and other (name inctuectriat to my option, An Lae Dread. U aerob' as irrentre of effinarroary wilt in the hat or art, au] the ~lion he WE anytime lathe United St", dearly ercrurtra en individual dertracetary eb-lity :n this kit Mr. Iron hu yea kertereerhanr goro sod recoensud for Ms usdag abod stad «peon dye modal, he fla nidalt appearing te the mreri prima* t‘a Wth:on :tubiletel, •oe around that world at a kV, MØ. Ccorteopoicrocit Maya !naps Mt. Solaria eartantra to ea» r dregs firet wore.] h:rn • ptoltiou as one of the leacto• awls and Ulage ZOOrdixistan 'workbag today. II la also my aptaacm that that ctspinarbt.thos sot:Nat:la lian 113tetn.ici tram' enn d:cetar, who collaborabts erieh the eat darin,enhed mØ0 and erhettrari elLertl, or:. ere ea :t•fickt,al of atraorchaary abQln and acrempt.tb,otto th in Nr an In brute! aperad a Da term work au the than Bean Jon Lai Ihnzorn1 emir heir!' Mae plemnal Sr* the Sam rut Random* bads to enteet tee an ter garnets ~dada Ear EFTA01122327 st 1 t LIMIS Vantona &reine Combi 75 Lown beklom Strooi M. Alba" Vi' a5479-000l at O-i Non-loomient Visa Pbatiosi aa betaalt ot kan Luc brand Der trof Madam- My ome is Nadia d110,1 moslim Promitet ot Montage Mrsieni 1 base jo »sr» «export moe *ad l am CUIISCInt `• ho meun wtth proemowatuilo all mor tbr werkt. Arend tro) dient* ini Elko Manonse. /nlant Rok/mans, laura tap. Ogili Tb* 145 . sediment. At. stmc1/4 t am qualefied to comonent om Mr. Jean Lor Brunei amor ais aa ut diwetor of eztraordbar. 'bib) It Y Dot tab- bstatne ot bis atelamationo or lito taimattse body dt work tint baboe utortionos and publishing csacrans artnad tht smid eflooarb MI/lie Mr Brunei', great bleet tor tben tenownied accourirtn. Mr. Ja lat Brood ia abn no absolute mort at tantiophint bis ctionts emetly tb based titelt trim. >ty perten.al opwaaiend Mr. Bruut t abs it sy fm du- to rninprreitnit hia atclamenians Priel by slantbobti theY oLw entolnli %blondheid. Acoordimk, Mr Brand b eu a potte:tata conunesd buit tainganation tor bs wort in umpires to ritus in tbr baba» Mr. ~In monument a brinkbbie nettot witha persunstme inneanor prosodie bib. He is oanionty Illemtatig mod *Mooi* gtinnilarinitb new omwipte for bis ellents and 1 ben acne to My os ond natal Mm spd bis ahnity. Oom tbr Lou rio .:! ila °definiet caner. Jtan Luc Rruirl ba ~bed Matkottewow of the S& Ska ut ~tob b te bettotry. Mr. Joan Lor Snood enjoys aa extra(' MI Mationsbip to ew 3c%throc. nip quallty ~ms Mei thomist' the braostiful mrt' he creacta, btw tbr time. Thrrefore. Ja Lus »rund a closet> ont cí the moot tabel praatton* waarna in te ~kl toddy Hooit forward to ~be enne of bs week b tbr Sult. Ilbeinty 'tas, Naden Cartovo ~14TO EFTA01122328 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 EFTA01122329 Reconimendatten letter 22/09/14 USC'S Vermont Secure Center 75 Lower Weiden Street St. Albans, VT 05479.0001 RE: O-1 Non-immigrant Visa Petition on behalf of Jean Luc Brunel Dear Sir or Madam It is an elittittfie 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 prniessionaily for rieveral years through our work together and, in my opinion, he is an extrfrmcly talented individual with superb professional reputation. He is an !extracirdinur ily 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 belt 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. Brunel 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 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 od contact me should you h-we any questions regarding this matter. Thank you for rtiiir time and efinsideration Sincerely, Vladimir Yudash EFTA01122330 FiGaro • MI .1 ***** eV ranee 431I1' 17, arm Department at leans tan? Security United Stoke Citeenship aW Immewation Sienras Vent. Stern tens. Hedetifon Stint Saint Albers . VT 05470 :era* • if 0-7 Eattaceertair Malty as aw Art Onectot G1'41'404 Caantnatoi cal behalf of 1000.14c War iientl•Rom Iniote4 .stin Mn .tar. ar.t.a In 7 et"*' r Titral•ret• •V4 7S 1 . • or Ditecfrav e•rt.1 %en/ r.arregelle4316 e.."1•4 Lena? V,:iett AI .2 1 3 .eri tcitiirt•J1.7.4 VC. Olean Va:cet, cw'j 'cots os I— ga ree very late a czetil e arn, the rrstdell mtgs. Gives, h.* wow rya lave') * Inman ?••• ran, rtOt Jac:tie raj 0-.3 rearsaantecl ••:04, mOdfirs Itvoot";•,. to • .oss. ::rAil, .03) ter he rive nos persarillSol inarichorl 1:4100v !apayrOng Con! riot'? ajrc.r.. ,n sit to 967. to rington Is int 41 orkz.niod moo* , CO,Ctiavoo Stria leacer4C.:ripte t mr.Ognot Como MO few glarrlagin4 erre. r10110904 •h -ere cr 4e, , ir- nrale• • r4 v 7e• not 14, •ton”): , is -re 799.7n - n IIIa related is^ qttc s i C4 the; 11'..a..,74.? I). itatensav Ct)rtirfrt . ft tr. a raw! e ittruolis 1 inettC4 kiktvv Fri` Ctn.% T.Xeitare hrh Wah :ern Cl ?urt:SreCt of 4 3:rair. z ;:z-o-cacer es yo,je sovlbe 4zerritt pip ftazrzcs bAcre Clara. saner t. t:1 7-er iits ewer • re* Mara r eP ate tkure elm •••••tr-Ter KC, A1114.• KOMI" retPen Urn. eare?..7 aietixsci heel* n '73 77,2-7 * in 0) 0 ecteactoti bat,rrim 10, 1•0 - In • • . nos awn. copect ng c..v) hao..aixaM Or ht00 6171n0 . • ' Kaki' 4.0 " 01 40: 10 1 0t OS '•utatt mu. _ 0.ta.210“ ea QS' grotto- mor ..end unman 'mu sif-7.7.;,- 2 -77-41n* ' ad 10).04 1•fl 'net W F,04, Mawr .0 afeell s vsperitipss 1••er is >nt3 14:14-4firc: lerprecv:=, 3. ."1010 , Lvjuormic evil-0 14ra e4”.e. images n A -.)1 610 0 ,0 tYv>I *DIP PrCr+' letit= sr :11.10 4e1 ervi RIO( ttni ObYth V , trIte theihnho Liget' Jr! • .3•.-.7 t ill Fria* ' 4, , .•..0 tr'rla ell01.10n4:a r. 4 tee' •A• jecr I,.v er.,re coartmc• TY: "5 " ittenti 'anal 19%-.4 1.11X:""strra Pr' s• -Km *Weir n the 'Ir. _•- ' solo rsh ntat ••00...h- • 4 • . •tro 0 v•: imove• err I an totem, :- 0 : . .a• . idea Ananntravia • 040 ,47,7 EFTA01122331 MODELWERK tt.1.% falkil Harritxxg 8 Jcy. 2014 Deportment of Homeland Security United Stales Ciburiship and kr- -rigroi!an Services Vermont Service Cer le- 30 tst-Aightor Sneer Sant Albans. yr 05478 Re. al Extroordiriary Atiiity as an Ar- Dime tz and -alert Cr>ordinotcr behalf of Jear-LL: Didier -renn-Fter,e ?rune' to whom rt 1V4t ty Concri As a President at Mooe!werk this *her is Ritornello() in support of fAC2 Models Miami. ..L.0 or behalf or Mr Jean Luc Brunel 'o work as a- Art Directs and 'alert Coo-emote, . M. Brunel *HIM an WitInOtiOr'r.li ri7P-00110,4 ci a vilbie. shatogx nehvceker who --. able a cultivate expert relationship management sk 'r n. order to conclucr burtess In a global ervronmeav, and tracer tecrotive deals. Mr. Brunel nos a long nit' -r9 n mancerng and adVerrisng mayor fashion campaigns InroLgho...it nir twenty-five yea coreeriin the tor ,:n business. Mr. Brune has developed wo-chvido. exc.usive tnodolirt rid comnelic canpagns. Some of terse motor covntic compdgns includc 840 Therm with $4) tie m,-.-rierscri. PHA with Rebecca kart -. Christian Dias w,lri us Sernctrirovixoya. Mira-er Astor with mornica Mascot Chanel vnth :kiln; la VW; ttn.-Aerrineirn. Art,..14.. Pert.** win Th or Mugier. mid Cuchotoi Perfume with Atria SaUestro. Mi. aline has Su. developed mapc, foshiot, cc:mouton and sins deve-r. pea campaign Ira eiciusive cc-,tracts :eh tone est the ..yornis iou rcst- ,.>ei desiOrel V rh tit EFTA01122332 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 EFTA01122333 ratOot4M An 3314 1 DIOCOrnent of Mormons Secisey Wined Stot Menhir* one inirnlvalionSereces Vermeil Service Conner 3D Houcfracin noel Saint Abort VT Mire Re; 01 Taircoaray Ma 03 an Nt Denctor anal Talent Cootannt,), on bete* at lean-Luc Dicier lierrHrene Brunel to Won ti may Concern As a President or leaSalis Moos; Monovement the letter Is %Omitted in 20000a al MC2 models Mani. baC on behalf ofMr. Joan Luc Brunel tc tot ca an Mt Drec tor and loons Cocninator AR Moil halos tan i"emallenal mputaeOn all 0 Alb*. Ocitegic nenvorter atoned. to cullivolle expert reliant, monapernere sins otter b Conact daft In a 00001 IneKinmeal and laCter Woven deck. Mt bias notating ninon, h nolretn0 and caver'swg 'rigor 'ashlars oonvoues Treouglicul Fin nverey-Rre yea' cow in the fceNen tMlineli. fir We hal devokved emalretki Sectnte• rraticieing 0110 ammo& campaign& Some of Ihese agar camflc COrrPOign; Irak:kr [03 Them wen userrnockii Be mornersor_ PIun3 wills Rebecca eon*. °Man Dior min °Mina Sernonnarstaya. Margot An belt! Monica Bakal Chalet Mir Patel, MOO lactentmegn. Angel Perkin-be with Wien Muffler. raid Comas Rein web Atclo notestfa. We. burs nos also daunted trop fashion Corn peScins and Rai enveloped cornpelfrriond trulustre cartoon vat sons at the viola's top taHu.. (*signers such as Yves Satre =tent Qionet ChatiiCs1 Dice Gum node. and Mae .0000136 . _ . 4,34mtarJ 4•0"...1.4 iimpi af 1411 Tic. .3013i ana gag f./1 711 1411. • pato natalieffnialek Mr ...I'd Rig teS003.02W4I. PARV13) MICA Oa MAW/ ..tr.s .t.j.t; =sic EFTA01122334 Ciarbn TO )2ar extenewe ~inn' Quali6cation% ha eater as an indlvicta vat =Mac *Ion and anew lcienli Mai netted han b%1 109 toy~ ..Win !ti ~mart r the On+ cd Slot Shoe14 year nave any queslIons abut fl an WC &anal *KalificatIrint Peel tee to contact rte. EFTA01122335 wean. Mteradier t*. sow VIC yeome O n Senm Corder limn welder. Sine( St. nTh°01-W0S4alkaimi Od VS Mimeos ea behalf of Man Lae Itbet Heartitene Brunel / war Ws letter In strong support dal/Jean Luc Illninetv applititim for a non immigrani Ma to this country. ! am commis diaimIlastratore Cleo in Studio PP. !hese been eked to wane the prideMnnal credentials of Ma Brunei. and it I. my professional opininn that Ma Brunel is an Mt Dania and Talent Coordinata d tattatardinary ability oho ranks among the call parentage of !oral" pick at %ref top of hn flrid haw Rae lint-hand Mr Ms Inc.' viierial expertise in the field. Including tawny.. pixductinit conrchiution, and Clt direction fir Moots Mr. Brunel it cinsiderrd by throe in our bdixtry b helan extrionlin3r, croalior direelos talent, pimento to the (Clan ad related Imhof's... In my personal dealings with Mt. Jon lax Brunet 1 found him to br thoroughly prnfmacional ad capable of bring utilized in connectivo %vitt, • vilde range of native "%object maw" an OM' amignnlent toe his die Intuitive ability In provide hoot what's needed in cot-y am:ion Wtlb sin particular creator procim and pcniamai excellent DZIllagelittn I 3rd operational AIR% that cane from his vein: of exprrienee. Many people do not understand that behind retry marcdul itilvcrticing campaign and !Win, Mom net an creative met *MI war who an' making sure that Ihr bus:nets operates efficiently by eaordinning dineran tasks between models. photographer. and monativg creative trams I ran honemly say that Mr. Brunel moninnik PIThes nirnat r ab extraordinare talent in to. Reid I cots an unmitigated ondorminvil be Mr. Jar lac BMW regarding ha visa application as a press of extraordinary aMhry. 714yr is an hui14 in my Mind than hls popittlanty and ability is the field will ally conlinue to Per In crate a cos rd c EFTA01122336 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 EFTA01122337 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 EFTA01122338 montage 51/21 st Li, caLs st.ci21. ,N i 7,1 ts., .11 • 1. • • i i valt Smier tente I 15 larer ~bm 51 ffs. Albara, VT osewnoot Ut CI-1 tion-Immismat Viss ~km cio batt/ of jam Lue Small near Irr or Madam: Mykne ir Natt Canon 'adlast ~dent d &larmet Modet., I hair 3o ymsa of expertelev sod I am cut! :ca nt,:v Ip aopuet w11.11 profearmisals all oser the *vrid. A fr« at my Urta ia,ludc Sl1e kinenziar, Riresubs. laura %op. Olithi:s. The fik Røfta_ ....and ro an. As I ass qualltled to ooramtat on Mr. Jan IYr Ikunal'i raner as en ut dimt« of ~raudt/sari oblik It la eat ook hemn ot hia meda:atti= or his Ise~we body df work dit kaidoo athertisine tad publishing serseutine armod the ~id ener to fl at tir. *kunstis grent tabua lor Usett renowned aerorintii. Mr. item Lue Pai S tho 131 risi/ute «Fort st furtishms kis dier b with nactly the knase of their dette. >ty praon:11 appeteiotio of Ø. 2.narl nåe k sy for mr to cninpn-hrnsi Ø seelaarations Prqm sUndpoint, thay an eertalnly »ep matimed. Aacordbighi., Mr Brunet b b a patina to oornmetid simbie tarpraarloti for hb work as campus te reken ia the labben Nir.. Detltoi1 reriu i-1mo sa formidable anta N itu a periimabie demerinor Trote hia Hr ia vonstamp reir-urt: 'ri mad dirroloviag stimuiatingly new ocaaepti far hia din *ad I have toa to Sy oa and trur kim and hia aiglity. Over the mure ot his sekkane:id raner. Anm Lux Brunet has dietieguished Utmed! te arr of ett Slim fatbion art dincton- in te indwetry. Mr. Jar Loe liniaei vrjm-s 1113 extetordiesr, rikationship to the mit/betle. Tida ittailty =biet itself ~sti the ~ul 'mrk creittets tilet efta tiss Thcilifcrre, issa las Brund b darly oas of thr most Liktor() prottermit ~og to the world today. I look toneord to ~los .:roer of his bori; ta the foturt. 140eltsity kaos, 11/&1"«<:-.1,-, dadla Grava EFTA01122339 N< ”; FR( )NI SeoWast 17. »14 ~Ment Benroe Urin Te Larry elden Skal a ~ta VT 054794:C01 RE 0-1 Renarrgraire Vsa %tan on Indbit of Joan Lue Anse ost er ar Namn IhsoYld flie b «arid ny dal SOP suppen kv the Pereardirart *bent O-1 vist Plifion Submitted e7 lik Joen Lua &pel Au Ihe Senn relea Producer fa ~pc" I rm ocelerd b py eta rer Jedn Lue ~Iles in damrod ard air ceopmeer or ep hukret ~bm *ion Mann, eattleivar end utafra ~1 Nava Mod heil to the trip o' lys prelfeekort Throuredi Mr Jean Luc stade ihrirauirihrd armer, he na racarerd i high)/ impresthe bet cl profesone hamra and adwanunerni In Mi pilt! Asur ytre, På ~not tas Øfed benutitd Øe Ifug hare 3ppe mr ad In al nal i men pr aectn ramt of em smit rant public:a-Pm in the tirrld Pilen arves esi ter-tament to nis titt I sa a onnitleni Man to eta mene ard operationsl alclis of TnIfly crent,:r dnebial ar" ~ro riet ~aen end Pent opranaton It i Indra» ry pinn b ncgriza the rommliabir Want enst ochavorneols of Mr. Joen ta 13, unt Na ~egsa to «hiene bm Øft ~uka born the malt mnd" deyeepei creelheconcepe are kleis ei hk very trieue abilky b 00fatiCala, Tea carefd arabisk. tus inkaral =Un fnoomboo of ho fanta. a M Caf ad Mr Jer Lue entra Ir ialoctod fm c syrrgi flis ~is lyna fa bm Ificmsfry by ifra s'urnlØ men lot •inci• rae van. R con-barer/ Mad. he nei mortaci tatln sn of me bee~m1 ~Ile" fetla haus mod wcioninee h ste eit ao.• • dosbi ~løe« Stily the isra4 i' IM møy bal In ne prammar I ar arESWIly nei7y thst Mr. Jan Lue fat" repaeor nm ectioiml Inlernamtel ttehav Hir hei medhold s kral oftere Mehe barn nem deeetibe n*i mast Jar Lue Renta arbardineey tarer is **in Mersene tdrning beee finmalt. Liza Marin Setrar Tant Producer No røfl %iii•Ikettite .• ,`; ' fet" n it l‘••••INIIIej • EFTA01122340 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 EFTA01122341 FiGaro • ###### OP 0'00« III01- 1 anew owlet /um IT Mg Department 0040111018$10 liturgy Chad Malta Ciiiimahtp Mid Immigration Erma Vermont service Cotten 30 Houghton Seat Mietete Anions, VT 06478 :tie Sri- et O- faciartlitary Abbe es at Art Director and Tab r Cocerlocrtoi bettor or Jette-icte Oa& kleett-Rethe Suomi • iv me nocertnto m3 trier ttiritrel 5? .47 ie:t- e ,t-be veritbore io _ •ri at. Act (Sector ran intv.t Inv kneel Velle• AI a tort ezOeterealoT TITITet% !ACCEPT) 7e-, 'sett lea, be .•-eatist-ii vie+. sr i.cizemitii coins me moos, veNote• •;•.reen citew rya •••••••• Neetr.t. t.t• biret "es ti K[ 'Zee 2 -•1 tOCY•81Wde wee.* >4.,.• nee:WI Ile :TveCtot I • . JITIT Crier? 7, 'Von. wt.,/ :moo by eve bye‚ am cowries, ..natterea esnleartriblio Ccere. Kieen teiCTCTICee let* 9:67. :..elenejten wele orcroar te008. Peon:sir tea t., At' burei ixerniczynobit, a t ,yr,„, are as me few estr:r040.1 «TIC rearegal TOICC :71 CleVe Mtree• Irtit the rixte iorro OF 'hi intri •r• Teas‚ gr te teur 0:44.tmog dicer* Te-rwel.;*,e edeon'e.* z.yerer Cee2 o mow e sik t • sorrier- satv es. C"..eveJv ?..rstir>" tot iteridl Z.ceslat et rk.rviirce: at latrior. Torre Pc: ezver ‚Maur, Srept Fekee accacr vcre Care. »mom 1. bei-ire. ore ma rrst tcgaz•••c Lee fr ee f105 Cle0 e^e e .•:reett it .,.rile. >Tart Stare. 'Arica e4ti.r.ti be Were. .•:•••.1 Cl.r.rino Se wOunte. 08 arOCISCO00 beg:vile twine orei' prOteg00•*.t rye., ele warn. ocelean, •n03.ticriCt% reitare* ezzeltetin TU tau • reek Or • : e et es mtio *apt iminorie. u DA:iries; goor- i•en. tar from Sr..! Ogee* tiCtteet.* Tex ei 1.:te Pith cr'erlr — • Teel 1:1 eTI2T41 ',ewer ett e Teeter ter • e ;La, ::. • t:ttei aessera ' tee cone en308:-. a' neery ant A ales mu: Zr'.:..:(e i s n 'mi te) , cif , 7 , : tee Ye TITS ' :VV.: te:4 'Tee :Stirly•rg • cutrers..e *-Jtegeej vein fir te.:C iTJTele CDC —Jr:4*re; •: g ce *item rill Irv) eCteteriel •-t• Ten" te r too flee t P., terser r et . 'et • n'Oteir rt -1'24nCir ° 43.4. fin ee4 ee> • orlele,* • te. I ye:: •etree e.se4 1.*: ':Tee:.tee•• MO Sire . r • EFTA01122342 MODELWERK Hamburg 8 Julv. 2014 Department of Homeland Sect./ni United States Citizenship ond tir migr.i. un Services Vermont Service Center 30 ?-lough,or Street Sont. Albans. 05478 Re' O-1 Exhoordinary AtailY Of an Ar Dir ce •ce and •alert Coerdinatcr :n belli! of Jcsar-Luc Didier -.enn-Rene Brunei • ToWhorn st May Cancer.' iks a Pu.tsicient of macetwerk. letter is suorriffect in supper- of rAC2 Modets Miami. ..I.0 or behalf ot Mr Jear. Brunei to not as ar Art Director and talent Cocrdinate. Mr brune! •iolds an ff.tenallonal replottor m o viser, rotegic netwonter who obis 'ci cultivote expert relationshrp management order to conclue' business in a global erv•ronmen• and Miter lucrative dents. Mr. Brunet nos a long intory n martien° and adveriwng maso( lotion campoigns ttvougricut rus tiret -lier yeear careerjie tn9 fart n urstress. Mr. Brune has 0evelopea wcrtCwide excwsive inodeliN; and cosmetic compares. Same of the-se -naor cosrnenc carnidei'vr5 inctude Bio Therm with superrn0del tue rec''nersof,. MAS stem Kettecco Kornia. ChriStiOn Dia with Cholstou Seretonficriszuya Margot Amr with morico Bellucci. Chanel vire; Point_ ..‘1 Vu, , RtCkesitieln, . Arge- Perturine etth Thierri? Musper. and Cachait 'erlume witsi Mia ballestra. mr. &tire has alsu deveiOped major fashan cuir rxiigns anis (las oeve r Ped carr•Paigrl ord excluséve cc—au:mis r. -ne nt fte vry 1 itS rash c>n desborees WC h rvi EFTA01122343 Yves Son^ tov:rla Chanel Citishon Dor. Gt.:ci ;7••243/3. ana Mac 1Oc0bs. fn addition to Mr. Jean Luc !fru s everaive tus4neu obticOrions. career as an anorwlaan with Whew: voacan ono Creot:4e to nh hOs helped hirn find tap fashion modeb in reoreserl Jr the United Sto I $houtd you have any 4ueStbans °Oar Ma JeCir uc Bari I Quullicol.cris feel free to contact me. C I tmilii•NI tdosb Pres iAl m" u tvioddwerk Moitivinictifur t 'milli I EFTA01122344 MoOtill rett - 004 ar a 2171 >morenen, ot tara Siecome United States Cetterenia ond kornotahon Sentes Vermont Stavn Con* 30 Frovohlon Stier klint Abn Vi DUM ▪ 0-1 Øaxcsent ~mai Art økede: end Talent ccordnaror on behag ot Jeranstec Guler tierb-Rene Brunni To WhOrn rl May Comten% As a Preederrt Or rene MOdel management tro lenet it sunne/est In Suppart or mC2 moden Mars uC or tent or ta inn lvc advar ~man Ad olreC >Or and kipent Coorcinake Mr Ikoner hokk on ner e fm-x/tolk:n Or 0 vlebb rkateere nettverket nno h ote to culltbee expert reionorisrip moneetmen, skie in elta fo Conatt buens In o taletid tenvienrnom end troet 111~11 CreCti. Mr surt N:talong net« n markete; ana ce2v5rnseng glar" krthico Oompoon Trwcitghot.1 hit hventrare ytra colter In Pre fashion business me Brunet ha derscbced wanctelde. ~re midetn2 and eternetic comPOlprn 50/00 0/ 0•001 ^na COltra4C Con-pota litickne: thfrtri wflh Lpefm0clel se talral Ptte5 oter ReboOco VOM*" ~an dor te ChtlitIna Setronnonecova. ~gret Ada klan Manko Beltet Chr& vetin Parcia Von »temt sen. Anaee eedume- veitt, frir Me. and Caen/sel Potene vAlti Akta Balleora. hre. Bruner has aha demsoorto rnapr tanon compri.Qns end has developecl compiturel ond eickeent Controcis vet+ rome cd tc terrld's top kelten ~nr sch ds Veet sant loa ard Chartel. Cterstbn Diat Good Prodo. vW Mat J00001 EFTA01122345 et mem to Mt JOOd Luc knot s asterrarvie business 441:111tahtur no W00r as art hdtildUci with atilt Aron and CrOCA1v1 tO has MOS him kids foe ruction .riodefts 40 maned it the Unrfed Slates MGM Yee lab any Quagans abort bk. aeon Luc Mine* gorillkalleass Mei Woe to artloct tn0. SinMOW. Erk Mahan% EFTA01122346 Vermont Sank* Center Attn: Premium Processing Unit 30 Houghton Street St. Albans, Vermont 06478-2399 Facsimile Transmission To: LUIS FONT Pas Plumber lit Cl_ultbrial n and WeICC& Number CM pages including canon Date: September 6,2014 From: !malt Receipt Notion Verrnonl Service Censer— Premarn Processing Fax Number 802-26S-1778 V5C PPEWt A PROCESSNGSD,CGOv Meted you tell bid a cqy ot CU arson conc./twang your case The aortal decision we Ldiow via man r elves to appeal as decision appeal bins we be included —important— Impatanrimporlarrimpatant— If resealing b AR/west la Evidence or not to Deny Insure you nate a copy ci the decision amnia* btraing you cane page and Made the total flutter d pages preluded van your response Please include the case mop( natter (e g EAC01 CO3 1234) with el avresponlerce Ensure alien resgadng to Ms request That you to nor response to our NEW FAX NUMB° youosh to mail a response. a must be sot to tut VSC Premium Poossing lid al 30 it. gnion Street St Abatis VT 12428-2339 Do not sand your response m the 75 Lower Weben Street adchess. as that vs' Cause delays and as rot raw We pram access% clock tall the response n derailed as a prensum peConeng CAW tee 8 CFR 80:60l1 103 R8H111 Stionnsion of evidence in InigOratt to a Seems request states Modem. walled In response to a Sante opal must be sttmded at one time The stemession d oh,- some or the restated evidence will be constued a request foe a decocn based on the record TM coneencatee n Wended let The Mk toes eine novdis to whom 1 S RtIblent0 erdmey Wan rill0rtbibte net Renamed cceddeMe zed eon, kern asebien ens" eppleebe ere II tee Naar al nes co nereet i r set pie pumice Tapirs er ea negenee a GPM in &tang he eterrnanClion la Me weeded MOM tar sr Wen Wend sal Puny atumnarce risamon a *ono 04 dm ecererseecolol my be vary serabies It veto mused be cannoneer. • erne one Indy We under trils•dabb/ by Idepbone end Mem me tofnmincalar el ma ants one dvtaw son hew own nue yei yetveCuScisnov EFTA01122347 US nip:berm of Hone laid Steamy S Citizenship and Insrrugratiun Strike) Next ant ten ?cc I DI -I Applkentflelltionet A I Appneationfteiihre Zention For A Nonunnunram Weaker (lorm11291 Nair., bete Au0v9 to 414 Ronnie Ruby Neenah« II »CZ MRS MAIO ;2( 1116 Fehtt TOM LW UM? 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Am sal all claims must i.e lulls supposcil Ity dhconsernry PINJOhlf Form 797 (8/03/90) Y Itt tit I l'si UKl1 EFTA01122351 FONT LAW GROUP. P A 3440 Hollywood Boulevard. Suite 415 Hollywood. F 1. 33021 Tel.: Fax: November 3.2014 Director United Stales Citizenship& Immigration Services Vermont Service Center 75 Lower Welden Street Saint Albans, VT 05479 RE NO TIFICATION OF WITHDRAWAL OF 1.129 PETITION NMIOUT PREJUDICE BY PETITIONER FAC-14-225-501103 Petitioner: MC2 MODELS MIAMI LIS Onielklem: JEAN LVC DIDIER IIENR1 RENE BRUNIEL Dear Sir/ Madam. Please be advised that this office represents the shove referenced petitioner and beneficiary in this immigration matter and a O-2X from our office is on file. THE PETITIONER. MC2 MODELS MIAMI LLC HEREBY NOTIFIES USCIS THAT IT WISHES TO WITHDRAW 1-129 O-I PETTT1ON 9EAC-14-225-50i413. The petitioner requests withdrawal of this 1-129 petition without prejudice Please note this request for the record in the above referenced case. We resped(Wly request that you send us verification of this withdrawal pursuant to the residarions ininainixl in X C.F.R. Sec. 103.2 fig On Kindly send our office a written ‘eritleation of this withdrawal located at: loot Law Group. P.A. 3440 Hollywood Boulevard. Suite 415 Hollywood. FL 33021 Thank you kir your attention to this matter. EFTA01122352 -- 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 EFTA01122353 they believe to be questionable companies. So far that has not been a problem but It could come up in the future. The fact that you are requested for so many scouting events in various countries and cannot promote yourself properly to promote MC2 in the press due this problem has it's own sent of repercussions in terms of our global branding. In short, it has had a terrible effect on MC2 all around. I really urge you to solve this problem and get this removed from the internet so we can grow for the future. I've fought for MC2 and been extremely loyal but I must confess that I have even been feeling inadequate and questioning my ability as the leader of the organization. I can only attribute the fact that we have scraped by in the recession and barely survived in the past to your hard work, my hard work, and the tenacity of both of us combined. I can only imagine that if I am feeling inadequate and frustrated over a lack of growth of our company that you must feel even worse as you have had much greater success in your career and have operated at much higher standards in our industry in all areas from reputation, respect, admiration and monetary gains. I can even surmise you are probably feeling a level of depression and I have seen it in your highs and lows and when you have voiced your frustration. While I know you well and recognize you don't really go for the kind of advice I will offer; however, I think you should at least speak to someone neutral such as a therapist or a counselor to let your frustrations out and if you don't feel better and are still feeling down or depressed to see a medical doctor for your condition. You are such a positive person I hate to see you fighting what you feel is a hopeless battle. It is not hopeless you just need find a way to get that information offline and begin to repair your reputation. In the end I am afraid the damages are a lot more than you realize but let's keep fighting and moving forward as we have no choke. Thanks, Jeff Jeff Fuller President MC2 Model Management USA EXHIBIT K EFTA01122354 : SEPTEMBER 18. 2009 :.) FROM: JACQUIE JOHNSON DATE TO: CC: "BRADLEY J. EDWARDS" SUBJECT: EPSTEIN - DEPO OF JEAN LUC BRUHNEL We have confirmation for Mr. Bruhnel's deposition on 1113. We will commerce at 10:00 a.m. rf that is ok with you. Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeldt Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauder 1 Tele EXHIBIT L EFTA01122355 —Original Message— From: Tama Beth Kudman Dale: Monday, Nove PM To: Jean Luc Brunel 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. Ill >let Michael know. >Sent from my iPhone >Tama Beth Kudman EXHIBIT M EFTA01122356 From: "Dr. Ro ce Jalazo" < To: Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Thank you, Royce N. Jalazo, Psy.D. Licensed Psychologist Dynamic Behavioral Consulting a DBA of Dr. Royce Jalazo, P.A. 1975 E. Sunrise Blvd., Suite 532 Ft. Lauderdale, FL 33304 Direct (With V Toll Free Fax: or E-mail: Website: www.DynamicBeh.com EXHIBIT N > EFTA01122357 DI %Mk N 11010R M. coNsta.nm. Flee hallwaPv eavelseal hs oe, Cams Pawns blensetlaid setae Drunk Bellarteni Coseellia MS Z. 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EXHIBIT 0 C Unmanned EFTA01122358 COMPOSITE EXHIBIT P - MEDICAL HISTORY EFTA01122359 EFTA01122360 EFTA01122361 BNH HOSPITALMR 31 H IsowunnathSwou ,n4c, te.e Iftngkok Nvning Homo Ittottpit0 MR. JEAN - LUC BRUNEL Tol 026:16.2700 FAN 112,-,14:!-01C; 9 EFTA01122362 H Isomitnau BNH HO .ine (Bangkok Nursing MR. JEAN - LUC Once Daily Before Be It May Cause Droves EFTA01122363 EXHIBIT Q EFTA01122364 44 12depariaart~. Fmnoii intabirg ~ot ownet Motto° Drumt who eo ovens Uw MC2 agency in Miami %och. taart alraja . a fl Mort and Bod themata ensmeed tri e_ petneemelibortiwpar enyeatividotaile <hap://poitionne abc, airWatancin-bortda-, weeen. te2nYl- tOr5FIM ata ccogi In Øl lbe mout ~ar rwm-up gist nood in Derfde palets aa repenod by weet ... Fronch modeling &panty 011~ JIBIllát410~1111i, MIOCCI-Cra te MC2 agency «uwe& ebt tic& en, yi oØ. ehttoRwierbe-abc.oce-iipa Vi.crobet 5 escort in en&ta Setvitar kne not Itt - tilonr; Miami Winch Vtailing Qsoirts tilnow mi**, poe& *wat Maat radio stations drop iplestaz fram . Fronth modeeng egenc.y mes Joienitue *new& who co-owne te MC2 Wreef in Mom' ... owitheirs ebt- so5-mia yi.cegnorth Rien tienrh-yeiiaten necate (nuon~aea.....4 ene onponly me ...4"c^ arp *sein> r - Slenktir Pratritafagin t 4 Mare aftan ewn ead. Insta ~wee we logaitywbe prakwannede French Mortelt].) agiVicy ~ne< Jan lme eninO, who ci3a1111 the MC2 nonet In MUM Bosch *Kefte inemehbion orgasme neta/(.n ~som VI Wan"- SIMI;lt! Escort Gina to_Flom12 t Ans- %nu, modenno non) taf Jeitntiot Iliensa, Mv.) 10 Al% the MC2 panty in Uien Bron Pidoweiono I oren Dina ler eau I Drap Roede Leien — meramosuedento !Lp." Wen !or y, or/ ertgliftrinitinrchno ra wraittipl 1,, uil), • asemt v;41. 'n Pktiridikkjall ~ei belab ~Maa too Na Stringe Abactea rome*, Ørne afirep sta cotienta libei IC2 ier in .. ~te r *nap .00~4114.e. ettriiiii.baiwit • F10114a..iectr.: ageg *iis EXHIBIT Q EFTA01122365 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 EFTA01122366 the events that she had with these men so that he could potentially blackmail them." the court filing said. "One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein's and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico. and the U.S. Virgin Islands," the legal pleading added. Dershowitz called the allegations "totally made up and totally fabricated from beginning to end." He said he was not in the places described in the filing at the relevant times, with one exception: he did visit Epstein's private island in the Caribbean on one occasion. "I was there with my family," the renowned law professor said. Dershowitz said in a follow-up interview after this post first appeared Wednesday that he's planning to file bar complaints against Edwards and Cassell for inadequately vetting their client's story. "I'm planning to file disbarment charges against the two lawyers who signed this petition without even checking the manifests of airplanes or travel itineraries, et cetera," he said. "I'm also challenging the young woman and the lawyers to level those charges against 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 EFTA01122367 While "Jane Doc #3" is unidentified in this week's 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 Britain's Daily Mail in 201 I. 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, U.S. 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 EFTA01122368 ---- 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 Sechtol 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 S EFTA01122369 Houston. TX 77027 P: F: EXHIBIT S EFTA01122370