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El IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. III IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA.
DIVISION 2 CIVIL IN DISTRICTS • OTHER CIVIL ACTION SUMMONS (b) Form for Personal Service on a Natural Person CASE NUMBER 14021348CA01
PLAINTIFF(S) JEAN-LUC BRUNEL VS. DEFENDANT(S) JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A YI.ORG CLOCK IN
THE STATE OF FLORIDA:TO EACH SHERIFF OF THE STATE, YOU ARE COMMANDED to serve this Summons and a copy of the Cotr4taint this lawsuit on defendant: in
To Defendant(s): JEFFREY EPSTEIN Address: -1.,*,---,; •Ef-i:e • I-f-2- -(Jble,4- *(40,,,t4t-f-AIP' 358 El Brilio Way Palm Beach, FL 33480-4730 .1"cl$F1..31
IMPORTANT
A lawsuit has been tiled against you. You have 20 calendar days after this summons is served on you to file a written response to attached complaint with the derk of this courL A phone call will not protect you.Yrxr written response, including the cose number given above and the names of the parties must be filed if you want the CODA to hear your side of the C.8541. If you de not filer your resporM time, you may lose the case, and your wages, money and properly may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. if you do not know an attorney, you may call an attorney reierral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response with the Clerk of the Court you must mail or take a copy of your written response to the "P(aintiff/Plaintiffs Attorney' named below. The central location of the Clerk's office at the Dade County Courthouse. The address for the courthouse, and branch locations are listed below for your comenience: DADE COUNTY COURT LOCATIONS the on also is
EiDade County Couitbouss (06) I Joseph Caleb Cantle- (20) 0 Notth Dade Justice Cordes (23) Room 133 Room 103 Room 100 73 Watt Hagler Street 5400 NW 22 Avenue 15555 Biscayne BM/. Miami, Florida 33130 Warm, Florida 33142 North allarri Beach. Flottda 33160 ElMimi Beach District Court (24) In Corti Gabtas District Court (25) II South Dade Justice Center (26) Room 200 Room 100 Room 1200 1130 Washington Amosie 3100 Pono: De Lem BIM 10710 SW 211 Stnied Miami Beach, Florida 33133 Coral Gables, Floricia 23134 WA* Honda 331/10 II Hialeah District (21) Room 100 11 East 61h areal Hialeah. Florida 33010 SERVICE
Plaintiff/Plaintiff Attorney JOE TITONE Florida Bar No. 203882 Address: 621 S.E. 5TH STREET, POMPANO BEACH, FL 33060
HARVEY RUVIN CLERK OF COURTS VIVRA Sikilumt: ir BY: , DATE ON: 1E6 0 0 2015
DEPUTY CLERK
AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE "If you are a person with a disability who needs any accommodation in order participate in this proceeding, you are entitled, at no cost to you, to the provision certain assistance. Please contact the Eleventh Judicial Circuit Court's ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification time before the scheduled appearance is less than 7 days; if you are hearing or impaired, call 711." to of if the voice _________
CLIC/CT. 070 Rev. 11111
Cleric's limb address: meat.
D EN LA CORTE DE CIRCUIT° DEL UNDECIMO CIRCUIT° JUDICIAL EN Y PARA EL CONDADO DE MIAMI-DADE, LA FLORIDA. 0 EN EL TRIBUNAL DEL CONDADO EN Y PARA EL CONDADO MIAMI-DADE, LA FLORIDA.
DIVISION DI CIVIL L _ OTRA EMPLAZAMIENTO DE ACCION CIVIL (b) NOTIFICACION PERSONAL A PERSONA NATURAL NUMERO DE CASO
DEMANDANTE(S) VS. DEMANDADO(S) HORA
A Demandado(s): Direccion:
listed ha sido demanded° legalmente. Tbene 20 dias, escrito, y presentarla ante este tribunal. Una LIamada presenter SU respuesta por esaito, induyendo el numero tiempo, pudiese peeler el caso pordria ser despojado Existen otros regtisitos legates. Si lo desea. poade una de (as oficinas de asistencia legal (Legal Aid Is guia telefonica. SI desea responder a la dementia por su cueeta, al o entregar en la mane una copia de SU respuesta a Demandante) y presenter su contestadon a la domande edificio de la Code del Candado de Dade. La direccion LOCAL1DAD CI Dade County Courthouse (05) 0 Joaeph Caleb Room 133 Roue 103 73 Weal Flagler Street 540 NW 22 hitiorni, Rcrioa 3313D Miami, Florida 1:1 kbarrd Eleach Cestrict Court (24) 0 c.aki oatkii Room 200 Room 100 1130 Washington Avenue 3100 Ponce MAarn1 Beath, Florida 33139 Cm( Galslea. IMPORTANTE contester la demanda adj crinsidere su defense, Sl usted no contests la denanda sin previo aviso del a un abogado, puede Referral Service) que aparIcen debera usted envier ofir (Demandante o Ahmed° la Mina del Secretario elta para su convenienci2: El Walsall Dtatrict (21) Room 100 11 Bost 6th Street Hialeah, Hondo 33010 nia, por debe a tribunal. Ikamar a en correo del en el
cordados a partir del recibo de este notification, para leiefonica no lo protegera. Si usted desea que el tribunal del caso y los noinbres de Las partes irderesadas. de sus ingresos y propiedades, o privado de sus denachos, usted consulter a un abogado inmediatamente. Si no conoce Office) o tin servicio de referenda de abogados (Attorney misrno liampo en que presents SU respuesta ante el tribunal, la persona denominada at)* como 'Plaintiff/Plaintiffs Attorney" al Secretario del Juzgado. La tibial:ion central de de ta Code, y de (as sucursales aparecen en la Lists siguiente DE LOS 71IBUNALES DEL CONDADO DE DADE Career (20) 0 kWh Dade Judio5 Clatter (23) Room 100 Avenue 15555 Biscayne Elhod. 33142 North Marra Beach, Floeda 33150 District Cowl as 0 South Dade Justine Center (25) Room 1200 De Lem PM. 10710 SW 211 Street Fi011112 33134 Mama, Florida 331E19
Dernandante c Abogado del Demandante Numen3 del Colegio de Abogados: Direccion:
EL ESTADO DE LA FLORIDA: A cada alguacil del Estado: Se le ordena que hagen entrega de esta nolificacion y u copia de la demanda en este pied° at tlemandatio(s) mencionada arriba. la
HARVEY RUVIN Secreted° del Tribunal del Condado POR: FECHA
GornoSecretario Adjunto
Ley para Estadounidenses con Incapacidades "Si usted es una persona minusvalida gue necesita bacer arreglos para poder participar en este proceso, usted tiene derecho, sin gasto alguno, a que se le provea cierta apda. Por favor pong_ase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial uhicado en el Lawson E. Thomas Courthouse Center, 175 NW 1st Ave. 2702, Miami Fl 33128, Telefonos (305)349-7175; TDD (305) 349-7174, Fax (305) 349-7355 por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales; inmediatamente despues de recibir esta notificacion si el tiempo antes comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la voz, llame al 711." Sala o de la
CLK/CT. 070 Rev 11111
Clerk'es web cellintss: Ninny.
U AU TRIBUNAL DU ONZIEME ARRONDISSEMENT JUDICIARE DANS ET POUR MIAMI-DADE, FLORIDE. 0 AU TRIBUNAL DE JUGEMENT Er POUR LE DEPARTENT DE MIAMI-DADE, FLORI DE.
DIVISION CI CIVILE D AUTRE CONVOCARION (b) LIVRAI ON PERSONNELLE Cr ACTION CIVILE A UNE PERSONNE NUMERO DE CAS
PLAINTE(S) VS. CONTRE ACCUSE(S) HEURE IN
A (AUX) ACCUSE(S): ADRESSE:
Des poursuites judiciaires ont ete enterprises contra citation pour deposer use response mite a La plainte protegee. Vous etas obliges de deposer votre response nommees ici, si VDUS souhailez qua ,:a tribunal entende risquez de perdre is cause sins' que vote sataire, tribunal. II y a d'autres obligations juridiques at vous vous pourriez telephoner a tin service reference cfavocats Si votts choisissez de deposer VOUS-Mellie UM reponse expedier une copte de votre reponse ecrite au •PlairtifiPtairdirs reponse avec le Grafter du Tribunal. L'adresse l'adresse des succursales sort dans ci-dessous pour 0 Dade County Courthouse (05) 0 Joseph Czech Room 133 Room 103 73 Weal Flaglet Street 5400 NW 22 Miami, Florida 33130 Warr& Ficrida El ktierni Beech Dtstrict Ccurt (24) 0 Corot Gables Room 200 Room 100 1130 Washington AVellie 3100 Ponce SAWN Beach. Florida 33139 CCIAI Gebtee, IMPORTANT la data de rassignation de est insoffisant pour ci-dessus at du nom des ecrite dans le relai requiS. suite, aucun preavis ulterle vous no connaissez pas d'• rannuaire de telephones). cette formate, faire parvCnir ci-dessous at emegistrei L'adresse du trib 0 Htelesh District (21) Room 100 11 East 6th Street Hialeah, Flodde 33010 cede vous 3arties VOUS ur du vocal, ou votre nat,el
VOUS. Vous ci-jointe ecrite, vote votre argent, pouvez requerir ou a ecrite, centrale du wire convenance avez 20 jours consecutifs a partir a de aupres de 03 Irthurtal. Ull SkT1010 coup de telephone ac mention du nurnero de dossier muse. Si vous no deposez pas aotre reponse at vos biens peuvent etre saisIs par La les services immedlats d'un avocet. Si tin bureau dessistance juridique (frgurard a it VOUS faudea egaternent, en memo temps qua Attorney (PlaignaM ou a son avocet) nomrne bureau du Craftier est le Dade County Courthouse. DES IRIBLINAUX EN DADE 0 North Dade Justice Center (23) Room 100 15.53 Biscayne Btvd. North Wand Broth, Florida 33160 (25) 0 South Dade .histice Center (26) Room 1200 10710 SW 211 Steel Wane, Ronde 33189
ADRESSES Cotter (20) Avenue 33142 District Court Be tem Stmt. Florida 33134
Plainte/Avocat du Plainte Numero de barreau de la Floride: Adresse:
LTAT DE LA FLORIDE A chaque sherff de retat vous etes oblige de presenter cette citation et une photocpie de la plainte ce document sur rarnuse (e) ci-desus. ie
HARVEY RUVIN Greffier de Tribunal ' PAR: DATE ON:
OOMVE GREFFER Af1101NE
.. ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE l' ADA "Si vous etes une personne handic,apee qui a besoin d'accommodement pour pouvoir participer a cette procedure, vous avez le droit, sans aucun coot, d'avoir de l'aide a disposition. S'il vous plait contacter le Coordinateur de l'ADA du Tribunal de l'OnYieme Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW 1.3t Ave. Suite Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 moms 7 jours avant la date de comparution au tribunal, oubien immediatement avoir recu cet avis si la date avant la comparution est moms de 7 jours; si vous avez incapacite pour entendre ou parler, appelez le 711." votre 2702, au apres une
CLKJCT. 070 Rev. 11/11
Cient's eth address: anew
erk.com
0 NAN TRIBUNAL ONZYEM AWONDISMAN JIDISYE NAN E POU MIAMI-DADE COUNTY, FLORIDA. 0 NAN TRIBINAL E POU TRIBINAL NAN MIAMI-DADE COUNTY, FLORIDA.
DIVIZYON El SIV1L 0 LOT KONVOKASYON POU KA SIVIL (b) DELIVRE PERSONELMAN BAY YON DAMN NIMEWO KA
PLENTIF(S) VS. KONT AKIZE(S) LE
AKIZE: ADRES:
Yo entre yon aksyon kont oumeum. Ou genyen 20 jou grefie tribunal-sa, yon reponce pa ecri attache avec plent4a. ecrifo ou mete numero ka-a ki sou tet pagela avec nom position-0u cou ka-a. Si ou pa enregistre reponce-ou ou capab pedu l'agen ou ak byen ou. Genyen lot demande. avoka, ou ka rele sevis id rekomande evoke, ou biro ede Si ou shoisi voye yon reponce pa ecri oumenm, ou supose pa ecri pou avoka pleyan ou pleyan-yo ke non-li ama-a Tribinal. Adres santrat biwo Sekrete a se Dade County pou ou kaiwenn ye alez: MIRES TRIB1NAL 0 owe ccuity C,osethouse (05) CI Joseph Caleb Center (20) Room 133 Roam 103 73 West Ftagler Street 5400 NW 22 Avenue Warm, Ronda 33130 Ward, Florida 33142 Ell Miami Beech Distri:1 Cool (24) LI ower Saida* Dielnct Court Room 200 Room 100 1130 Washington Avenue 3100 Porto% De Loon 131,41 Mani Bomb, Floada 33135 Coral Gablex Florida 33134 En pou enregistre cevan Se yen repenite si ou vie ke tribunal-la la pa enounce-ou en de suit. Si ou pa !oriel on pote on copi response ki localize nan avek lot tribinal yo nan lis ki CI lilal DtstOot (21) Roam 100 11 Eest 6th Sliest 1-11sioa1i. Rod& 33010 pa kende yen, yen --krete .nba a
kalandriye apres ou recevoi sornasyon-an Yon apei pa teleran ka kapab protege-ou. moune-yo ki sou papie-sa oblige ecri a l'heure ou capab pedu ke-a san tribunal Ou ka besoin telefone yon avoka tout legal (ki nun lis liv telefone). en mem Ian poste en mem tan poste et enregistre reponce-la nan tribunal-la Courthouse. Adres tribinal la, ak adres NAN DADE COUNTY El 1-4.111 Dade Justtos Genie/ (23) Room 100 15555 Btscayne Blvd. North tani Reach. Fltrittl 33160 (25) 0 South Dade Justice Center (76) Room 1200 10710 SW 21) Street Welt Ronda 33189
Plainta/Avocat du Plainie Numero de barreau de la Floride: Nimewo manm avoka a. Address:
ETA FLORIDA: Pou Chak nan eta a yo odone ou pou bay akize a (yo), non I ekri anwo a, manda sa a ak yon kopi yo pate an pwose sa a.
HARVEY RUVIN Sekrete Jenemi Tribinal La BAY: DATE:
SEKRETE
LWA 1990 POU AMERIKEN KI ENFINI ANONS POU ANIERIKEN KI ENFINI "Si out se yon moun ki enfim e on bezwen akomodasyon pou on patisipe nan pwosei sa a, on gen dwa pou yo ba ou kek ed san on pa gen pou on peye. Silvouple ko 1 takte KowOdinate ADA pou Tribinal Onzyem Distrik Jidisye a nan: Lawson E. To omas Courthouse Center, 175 NW 1st Ave., Suite 2702, Miami, Fl 33128, Telefen (305 349- 7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan on gen randevo pou on paret nan tribunal la, oubyen imedyatman le on resevwa notifikasyon sa a si o gen mwens ke 7 jou pou ou paret nan tribunal la; si on gen difikilte pou on tande o byen pale, rele 711."
CU(/CT. 070 Rev. 11/11
CiefleS web adriress: www.vgp
erk.oam
Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM
IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR DADE COUNTY, FLORIDA
CIVIL DIVISION
JEAN-LUC BRUNEL, individually,
and MC2 MODEL &
TALENT MIAMI, LLC
Civil Action No.: 14-21348 CA 01
Plaintiffs,
VS.
JEFFREY EPSTEIN,
TYLER MCDONALD, TYLER
MCDONALD D/B/A/ YI.ORG
Defendants.
/
AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND
DAMAGES
COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami, LLC, by
and through undersigned counsel, and sues Defendants Jeffrey Epstein, Tyler McDonald, and
Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable relief and defamation, and states as
follows:
1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler
McDonald d/b/a Yi.Org do business in Dade County, Plaintiff Jean-Luc Brunel resides in Dade
County, Florida, and Plaintiff MC2 Model & Talent Miami, LLC, has an office in Dade County.
The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County,
Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there.
Florida Statute 47.011.
2. Florida Statute 48.193(1)(a)(1) ("long-arm") authorizes service on both out-of-state
Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org).
1
3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen-
thousand dollars ($15,000).
FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN
4. Plaintiff Jean-Luc Brunel is the owner of Plaintiff modeling agency known as "MC2
Model & Talent Miami" ("MC2"). MC2 began operations in October 2005 and has offices in
New York, Miami, and Tel Aviv.
5. Defendant Jeffrey Epstein ("Epstein") is a hedge-fund manager with a residence in Palm
Beach County, Florida. Defendant has been the subject of significant media coverage due to
charges brought against him involving sexual contact with minors. (Composite Exhibit A
attached).
6. Plaintiff Brunel and Epstein have known one another since the inception of Plaintiff
MC2.
7. Plaintiff Brunel operated his modeling agency, Plaintiff MC2, without incident until
Epstein was first charged in Palm Beach County with unlawful sexual contact with a minor in
2006. He was convicted of soliciting prostitution from a minor and sentenced to eighteen
months in prison, of which he served thirteen months. He remains a registered sex offender in
Florida as of this day.
8. First, after the initial criminal charges against Epstein were filed in Palm Beach County,
Plaintiffs were widely implicated in the media as being "linked" to Epstein. These false stories
caused both Plaintiffs a tremendous loss of business.
9. Plaintiffs lost multiple contacts and business in the modeling business as a direct result of
Epstein's illegal actions. For example, several photographers will not work with MC2 due to the
2
adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking
Plaintiffs with those activities; namely, sex trafficking. (Composite Exhibit A).
10. One example of such a photographer was Michael Avedon, who worked with MC2 on
photo shoots. Avedon stopped answering Plaintiffs' emails and phone calls after having known
Plaintiff for some time. Upon meeting Avedon out one night, Avedon stated to Plaintiff Brunel
he had "found out some information" from some friends of his and that he could not associate his
name with MC2.
11. This statement by Avedon was no doubt a reference to the alleged and false links
between Plaintiffs and Epstein's illegal activities with under-aged girls. This incident clearly
illustrates an example of lost business on Plaintiffs' behalf.
12. The second example of a business relationship that was terminated due to Epstein's
intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos
Model Agency. The owner stated that the model to be placed with MC2 "found some article in
Internet, which changed her position and she preferred to be placed with another agency." This
was relayed to Plaintiff Brunel by e-mail dated October 15, 2014. This amply demonstrates that
Epstein's intentional & illegal activities continue to cost Plaintiffs' business income. (Exhibit B
attached).
13. A third example of a lost business relationship can be found in an e-mail dated October
17, 2014 (Exhibit C attached). The director of the 1 Mother Agency, Vladmir Yudashkin, states
that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs' will force
her into illegal activities. The model bases her fears upon the stories on the intemet falsely
implicating Plaintiffs as being involved with illegal activities with young models. This is
3
another example of a false link between Epstein and Plaintiffs, costing Plaintiffs' business
income.
14. A fourth example of a lost business relationship can be found in a second e-mail dated
October 17, 2014 (Exhibit D attached). Manuela Martinez of Mega Partners, a Brazilian
modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff
MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs.
This reference is clearly to the false allegations online regarding sex trafficking that were based
in the false link between Epstein and Plaintiffs.
15. A fifth example of a lost business relationship can be found in an e-mail dated
on Plaintiff's behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agence
France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world-
wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2.
However, due to the adverse publicity surrounding Plaintiffs as a result of Epstein's illegal
activities, Plaintiff Brunel was forced to forego (and lose) this business opportunity because he
needed to keep a low-profile at this time.
16. A sixth example of lost business due to Epstein's intentional and illegal activities can be
found in an e-mail dated December 12, 2014. (Exhibit F attached). Michael Sanka, a talent
scout who had worked with Plaintiffs for a number of years, informed Plaintiff Brunel that he
cannot sign any new models for Plaintiff Brunel's MC2 agency due to the false sex trafficking
allegations online. Sanka goes on to state that Plaintiff Brunel's MC2 agency will not attract any
new models if Plaintiff Brunel does not clear up the false allegations.
17. A seventh example of lost business due to Epstein's intentional and illegal activities can
be found in an e-mail from Fox Fashion Agency (Exhibit G attached). This e-mail clearly states
4
that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems.
However, because of the false internet trafficking links between Plaintiffs and Epstein, Fox states
that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up.
18. Before the false links between Plaintiff and Epstein surfaced, Plaintiff Brunel was
earning a great deal of revenue from MC2 Miami.
19. The false links between Plaintiffs and Epstein began to surface online in about 2005-
2006. Then, in 2006, Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs
then made an investment totaling one-million dollars with Elite Paris, to start a company.
20. Next, Plaintiff Brunel started the company, "E Management", to work with Elite Models
in Paris, Plaintiff had to close it almost immediately, because Elite didn't send any models to
Plaintiff MC2 for fear of being linked to Epstein.
21. Because the false links between Plaintiffs and Epstein began to gain strength online, Elite
Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment
of one-million dollars because of this loss of business.
22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar
loss.
23. Additionally, a former financial controller of MC2, Maritza Vasquez, stated in a 2012
deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under-
age model. (Exhibits HI & H2 -Transcript of Deposition of Maritza Vasquez).
24. Maritza Vasquez was fired from her job at Plaintiff MC2 for embezzling company funds,
and had criminal charges filed against her (Composite Exhibit I attached). She was also the
source of the false information linking Plaintiffs to sex trafficking in the articles written by
Conchita Sarnoff of the website Jezebel (Composite Exhibit A. p.2-7).
5
25. The deposition testimony of Maritza Vasquez referred to above clearly demonstrates that
Plaintiff Brunel has clean hands and was never involved in sex trafficking. All of Plaintiffs'
damages came solely from Epstein's conduct.
26. Additionally, Plaintiff Brunel has had significant delays in obtaining his visa to come to
the U.S. These delays were also the result of the false link between Plaintiffs and Epstein. As a
result of these delays, Plaintiffs lost a considerable amount of time & money. International
travel is a significant component of Plaintiff Brunel's MC2 modeling business. Plaintiff Brunel
has been forced to cancel his latest visa application as a result of the delays. (Exhibit J —
Composite Visa Does).
27. As a result of the notoriety and tremendous publicity surrounding Epstein's criminal
charges, and the media linkage of Epstein to Plaintiffs regarding illegal activities, Plaintiffs lost a
tremendous amount of business and revenue.
28. Plaintiff Brunel's agency MC2 has lost millions of dollars in revenue since the media
revealed that Plaintiffs and Epstein were associated. In fact, Plaintiff MC2 was worth millions of
dollars; now, due to the illegal actions of Epstein, MC2 is almost worthless.
29. At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the
Epstein's illegal activities.
30. As a result of Epstein's illegal activities and his association with Plaintiffs, Plaintiffs
continue to lose money and suffer damages to this day. (Exhibit K attached, Jeff Fuller email,
11-12-14).
31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to
what it was once worth — money that the Plaintiff Brunel does not have.
6
32. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names
never having been cleared from the massive and totally negative media coverage involving
Epstein and his illegal activities. Plaintiffs have been, and continue to be, irreparably harmed by
these false internet-based links to Epstein. (Exhibits R & S attached).
33. Second, Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in
anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct
advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done
for the sole purpose of delaying Plaintiff Brunel's deposition.
34. As a direct result of Plaintiff Brunel's travels, his deposition was delayed twice. When it
was finally scheduled for November 2009, Plaintiff Brunel was in fact available (Exhibit L
attached). However, a medical emergency in the family of his attorney further delayed this
deposition (Exhibit M attached). It was never rescheduled and he was never deposed.
35. This was a blatant example of obstruction of justice in the criminal case. Epstein was
solely responsible for telling Plaintiff Brunel to leave the area. Plaintiff Brunel lost a huge
opportunity to clear his name, and that of his agency, Plaintiff MC2.
36. Third, as a result of all of the facts stated above, Plaintiff Brunel was under tremendous
psychological pressure throughout this period of time.
37. This psychological pressure resulted in Plaintiff Brunel avoiding business contacts as set
forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts
during this period of time.
38. Plaintiff Brunel became extremely withdrawn and anxious at this time.
39. Epstein's conduct was the direct cause of Plaintiff Brunel's psychological state. The
press was reporting extensively on the lurid details of Epstein's illegal activities with the under-
aged girls.
7
40. As stated above, the press reports were erroneously connecting both Plaintiffs to
Epstein's illegal activities. (Composite Exhibit A attached).
41. Epstein's illegal activities were outrageous and extreme; they involved receiving
massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the
girls with a finger or object; or full-intercourse.
42. These activities described above caused Plaintiff Brunel severe emotional distress. In
fact, Plaintiff Brunel has recently undergone psychotherapy with a local psychologist, Dr. Royce
N. Jalazo, as a result of Epstein's actions and the negative results on his business. (Exhibits N &
0 attached).
43. Plaintiff Brunel is emotionally destroyed as a result of Epstein's actions and the resultant
effects on his business. He has been on medications to deal with the effects of this. (Composite
Exhibit P — Medical History).
44. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly
retained undersigned counsel to represent him in this matter, and are obligated to pay counsel a
reasonable fee for his services.
FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER
MCDONALD D/B/A YI.ORG
45. Defendant Tyler McDonald ("McDonald") is the owner/operator of Yi.Org and also does
business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org ("McDonald d/b/a Yi.Org").
Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service
based in Vancouver, British Columbia, Canada.
46. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting
websites that contained hyperlinks that contained blatantly false and extremely disparaging
information about Plaintiffs. (Exhibit Q attached - hyperlink screenshot).
8
47. These links clearly and falsely associated Plaintiffs with illicit escort services in the state
of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or
should have known, was false.
48. These links have damaged Plaintiff Brunei's reputation as an owner of a well-established
modeling agency with offices in New York and Miami, Plaintiff MC2.
49. These links have also damaged the reputation of both Plaintiffs.
50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss
of revenue to Plaintiff MC2, and accordingly, to Plaintiff Brunel.
51. Plaintiff MC2's revenues have fallen to a mere fraction of what they were before the
appearance of the links on Yi.Org.
52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of
the false and negative information that damaged Plaintiffs' reputation and directly caused
damages to Plaintiffs.
53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, both names still
harmed by the false and negative association with escort services in Florida.
54. Accordingly, Plaintiffs have been severely damaged by information on websites hosted
by Yi.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and
McDonald.
55. The information disseminated by the websites hosted by Defendants McDonald d/b/a
Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged
involvement with escort services in the state of Florida.
56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the
names of Plaintiffs with regard to the false and defamatory information disseminated by the
9
websites they hosted.
57. Plaintiffs continue to do business to this day, their names never having been cleared from
the negative information disseminated by Defendants McDonald d/b/a Yi.Org and McDonald.
58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and
McDonald, and have accordingly retained undersigned counsel to represent him in this matter,
and are obligated to pay counsel a reasonable fee for his services.
COUNT I — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO
DEFENDANT JEFFREY EPSTEIN
59. The allegations contained in paragraphs 1 through 44 above are re-alleged and
incorporated herein by reference.
60. Plaintiffs have lost a significant amount of business revenue because of the actions of
Defendant Epstein set forth above.
61. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages
suffered in the form of lost business revenue due to the actions of Defendant Epstein.
62. Accordingly, Plaintiffs seeks to become whole by the payment of damages by Defendant
Epstein to compensate him for his losses.
WHEREFORE. PLAINTIFFS request judgment against DEFENDANT as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
COUNT II — OBSTRUCTION OF JUSTICE — EQUITY - AS TO DEFENDANT
JEFFREY EPSTEIN
63. The allegations contained in paragraphs 1 through 44 above are re-alleged and
incorporated herein by reference.
10
64. Plaintiff was forced to commit illegal acts by traveling away from the sight of the
deposition and during the time period of the deposition.
65. Defendant Epstein attempted to subvert justice and this attempt contributed to the
destruction of Plaintiff's business, Plaintiff MC2. Plaintiff Brunel lost substantial time away
from his business and incurred expenses in following Epstein's commands.
66. Plaintiffs were substantially damaged as a direct result of Epstein's actions.
WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
COUNT III — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON
PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN
67. The allegations contained in paragraphs I through 44 above are re-alleged and
incorporated herein by reference.
68. Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by
engaging in illegal conduct with under-aged girls, which was falsely linked to Plaintiffs.
69. This illegal conduct was extreme and outrageous by any standard.
70. This extreme and outrageous conduct was the direct cause of extreme emotional distress
in Plaintiff Brunel.
WHEREFORE, PLAINTIFF BRUNEL requests judgment against DEFENDANT as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate
II
COUNT IV — EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS
TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG
71. The allegations contained in paragraphs I through 3 & 45 through 58 above are re-
alleged and incorporated herein by reference.
72. Plaintiff, through his agency MC2, has lost a significant amount of business revenue
because of the actions of Defendants McDonald d/b/a Yi.Org and McDonald set forth above.
73. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages
suffered in the form of lost business revenue due to the actions of both Defendants.
74. Accordingly, Plaintiffs seek to become whole by the payment of damages by both
Defendants to compensate him for his losses.
WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
COUNT V — DEFAMATION AGAINST PLAINTIFFS — AS TO DEFENDANTS TYLER
MCDONALD AND MCDONALD D/B/A YLORG
75. The allegations contained in paragraphs 1 through 3 & 45 through 58 above are re-
alleged and incorporated herein by reference.
76. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published,
false statements about Plaintiffs using their domain hosting service.
77. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the
statements about Plaintiffs were false.
78. These published statements were read by the internet users who viewed the false
statements.
79. Plaintiffs' business reputations were severely damaged as a result.
12
WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
COUNT VI — EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS
TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A/ YLORG
80. The allegations contained in paragraphs 1 through 3 & 45 through 58 above are re-
alleged and incorporated herein by reference.
81. Plaintiffs have also suffered a significant loss of their business reputations as a direct
result of the actions of Defendants McDonald d/b/a Yi.Org and McDonald.
82. Plaintiffs have no adequate legal remedy to make them whole as a result of the damages
suffered in the form of lost business reputations due to the actions of both Defendants.
83. Accordingly, Plaintiffs seeks to restore their business reputations by the payment of
damages by both Defendants to compensate them for their loss of reputations.
WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows:
A. Damages in excess of fifteen-thousand dollars; trial by jury and
B. Grant other such relief as is appropriate.
Is/ Joe Titone
Joe Titone
Attorney
FL BAR #: 203882
621 S.E. 5th Street
Pompano Beach, Florida 33060
(954) 729-6490
(954) 941-2232 (FAX)
Joetitone708@comcast.net
13
VERIFICATION
STATE OF FLORIDA
COUNTY OF/f-i/--1-44/ /211.0
JEAN-LUC BRLTNEL, being duly sworn according to law, upon his oath, deposes and says:
I have read the foregoing complaint and all the allegations contained therlin. All such
allegations are true based upon my personal knowledge, informatio and belief.
I
(id!
JE BRL
Sworn and subscribed to before me this / day of4e2z,...,/-r , 2014.
PALO VALLAMES
Nanny Pal4c - Florkta
1 lir Caren. barn Oc.1 31, an B
Coarniala •Eg 211500
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NOTARY PUBLIC
6
14
COMPOSITE
EXHIBIT A
http://www.thedailybeast.com/articles/2010/07/29/jeffrey-epstein-feds-probe-possible-child-
trafficking-charge.html
Epstein Faces Sex-Traffic Probe
The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has
learned—and has widened the scope of its probe to include a famous modeling agency.
Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a
minor last week. But it appears his problems may not be over. Now The Daily Beast has learned
that:
• Federal investigators continue to investigate Epstein's activities, to see whether there is
evidence of child trafficking—a far more serious charge than the two in his non-
prosecution agreement, the arrangement between Epstein and the Department of Justice
allowing him to plead guilty to lower-level state crimes. Trafficking can carry a 20-year
sentence.
• The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling
agency appears to have been a source of girls from overseas who ended up on Epstein's
private jets.
Because Epstein's predatory habits stretch back many years and involved dozens of young-
looking girls, there may well be more evidence to uncover.
Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the
charges covered by his non-prosecution agreement, in which he agreed to serve a short term of
incarceration, fund the civil suits of named victims, and register as a sex offender. The victims
who accepted cash settlements in these civil suits agreed not to testify against him or speak
publicly about the case. However, new evidence developed by the Department of Justice on other
offenses not covered by the agreement, including allegations by additional victims who come
forward, could lead to new charges. There is no statute of limitations in the federal sex-
trafficking law, which was also enacted by the state of Florida in 2002. Because his predatory
habits stretch back many years and involved dozens of young-looking girls, there may well be
more evidence to uncover. (Several young women who claim to be Epstein victims have recently
contacted a Ft. Lauderdale lawyer, but to date no new civil complaints have been filed.)
• Conchita Sarnoff: The Billionaire Pedphile's Sex Den
• Billionaire Pedophile Goes Free
These new developments come one week after the publication of two articles in The Daily Beast
about Epstein's pattern of sexual contact with underage girls, which Palm Beach police began
investigating in 2005 and the U.S. Attorney's office then settled in a 2007 plea deal. The first
16
article quoted a deposition by then-Palm Beach Chief of Police Michael Reiter, in which he
stated that Epstein, a billionaire with many powerful friends, had received special treatment in
both his plea deal and the terms of his incarceration. Although federal investigators at one point
produced a draft 53-page indictment against Epstein, he was eventually allowed to plead guilty
to only two relatively minor state charges and receive a short term of incarceration: 13 months in
the county jail, during which he went to the office every day, and one year of community control,
during which he traveled frequently to New York and his private island in the Virgin Islands.
The Daily Beast has now discovered another instance in which Epstein apparently received
special consideration: As a convicted sex offender, he is required by law to undergo an impartial
psychological evaluation prior to sentencing and to receive psychiatric treatment during and after
incarceration. This is because child molesters tend to be repeat offenders with high rates of
recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a
report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone
has since been disconnected with no forwarding information.
The Daily Beast's second article provided details about Epstein's systematic abuse of underage
girls at his Palm Beach mansion, where members of his staff allegedly recruited and paid a
parade of teenagers, most of them 16 or younger, to perform daily massages that devolved into
masturbation, groping, and sometimes full-blown sexual contact. It also revealed a monetary
relationship between Epstein and Jean Luc Brunel, a frequent visitor to whom he gave $1 million
around the same time that Brunel was starting his MC2 modeling agency. Some of the young
girls MC2 recruited from overseas—often from Eastern Europe and South America—are known
to have been passengers on Epstein's private jets.
The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the
existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger, says he has no
knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully
complied with all state and federal requirements that arise from the prior proceedings in Palm
Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal
investigations, given Mr. Epstein's complete fulfillment of all the terms of his non-prosecution
agreement with the federal government."
Conchita Sarnqff has developed multimedia communication programs.for Fortune 500
companies and has produced three current-events debate TV programs, The Americas Forum,
From Beirut to Kabul, and a segment for The Oppenheimer Report. She is writing a book about
child trafficking in America
17
,http://www.thedailybeast.com/articles/2010/07/22/ieffrey-epstein-pedophile-billionaire-and-
his-sex-den.html
The Billionaire Pedophile's Sex Den
Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a
depraved world of thrice-daily massages, pornographic artwork, and hush money—that's only
now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive
exposé.
Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a
depraved world of thrice-daily massages, pornographic artwork, and hush money—that's
only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her
exclusive expose. Also:
• Nude images of young girls were scattered around the house and the bathroom soap was
shaped like sex organs
• Staff trolled for fresh recruits to make sure Epstein had two or three massage
appointments each day
• The house manager has been sentenced to a longer prison term than Epstein—for trying
to sell notes regarding massage appointments
• Epstein gave $1 million to his friend Jean Luc Brunel when he was starting the modeling
agency MC2
• According to a former bookkeeper, young girls were brought to the U.S. by MC2—often
from Eastern Europe—then traveled on Epstein's private jets
Jeffrey Epstein's loyal friends say that his prosecution was unduly harsh, rather than
outrageously lenient. They insist that his sexual habits, although obsessive and unusual, were
mostly legal and essentially harmless. As the police records attest, the girls brought to El Brill°
Way were routinely told they could "say no" at any time during a massage as Epstein escalated
contact in a step-by-step assault that was remarkably similar in every victim's statement: First
she would be asked to remove her shirt, then her pants. He would attempt to fondle her buttocks
and breasts as he masturbated, then bring out a large vibrator. There was sometimes digital
penetration, and the more willing girls were lured into full-blown sexual relations with both
Epstein and Nadia Marcinkova, who was referred to in press accounts and police reports as
Epstein's live-in "sex slave."
A former bookkeeper in the Miami office, who also arranged visas for girls traveling to the U.S.,
confirmed that MC2 girls became frequent guests on Epstein's private jets.
18
It's true that some underage girls may have lied about their age, and some came to the house
voluntarily several times—although, according to Florida statutes, none of that has any bearing