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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.
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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.
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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
4 Scrawl Throw* NSW Navy Mot
ps...i.......upeirimpnwepeopmempft
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
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.
- Conchita Sarnoff: 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 four—Sarah Kellen, Adriana Ross,
Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution
Agreement stipulated that they would not be charged. According to police reports and sworn
statements in the civil suits, all four women, among their other duties, worked to ensure that an
appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits.
Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who
was for many years Epstein's live-in partner, also recruited young girls.
Since his 13-month sentence for soliciting prostitution with a minor, Epstein has settled more
than a dozen lawsuits brought by underage girls. Seven victims reached a last-minute deal last
week, days before a scheduled trial; each received well over $1 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. He was fired, he says, for inadvertently drawing police attention to one of the girls
when she arrived at the house unannounced to collect money. He saw an unfamiliar "beater" in
the driveway one evening and called 91!. When he left Epstein'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
Unfortunately, he made the offer to an undercover cop, and was subsequently charged with
"obstruction of official proceedings" for withholding information that could have advanced the
criminal investigation of Epstein—which by that point had been settled in a plea deal. Rodriguez
was sentenced to 18 months in federal prison (Epstein was allowed to serve 13 months in the
Palm Beach county jail), and now awaits an additional sentence on Aug. 24 in federal court in
Miami for transporting firearms, another deal he says he made to pay the bills after he lost his
job.
In a deposition given for the civil suits, Rodriguez testified that he was instructed to always have
$2,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters
such as Haley Robson 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 Marcinkova "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, Model: The Li:5.g). Business of
Beatitifid fPnnen. 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
$1 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 Bruners activities,
20
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 Conchita Sarnoff's oriuinal report on Epstein.
Conchita Sarnqff 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 Heington Post. She is writing a book about child trafficking in America.
21
http://fashioncopious.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-Trafficking 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 Marcinkova
'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: buying a 14-year-old Yugloslavian named Natalia Marcinkova
from her parents in order to keep Marcinkova 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
http://bettyfokker.wordpress.com/2010/08/20/hes-helping-others-get-away-with-child-sex-
trafficking/
He's helping others get away with child-sex trafficking
Posted on August 20, 2010 by Betty Fokker
Let's discuss that billionaire douche-face child-rapist, Jeffrey 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 ki.€14ie-pefn-Fifig 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.
I 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 lighter 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
http://zawkencom/5600294/reeently-freed-sex-offender-jeffrev-enstein-may-face-child-
trafficking-charges
Recently-Freed Sex Offender Jeffrey Epstein May Face Child Trafficking
Charges
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Expand
Jeffrey 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 with Bill Clinton, having an egg-shaped penis, and
being a vindictive pervert, can't be prosecuted again for the charges he copped to in his plea deal.
But according to The Daily Beast's Conchita Sarnoff, 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
http://www.huffingtonpost.com/20 I 4/06/03/j e ffrey-e pste in_n_5439407.html
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. Justice 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, tiling 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 efforts begun in the 1960s to give crime victims more of a say.
25
"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.
Some 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 Matt Alexrod, a former federal
prosecutor now in private practice in Washington.
26
http://www.huffingtonpost.com/conehita-s-sarnoff/ehild-trafficking_b_1269748.html
Conchita Sarnoff
Communications expert
Regulating Modeling Agencies to Help
Prevent Child Sex Trafficking
Posted: 02/10/2012 8:49 pm
In 2010, Jezebel, an online site, nublished "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.
Brunelts 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 511" 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
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 Bruners 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
Journal magazine. In that stor‘ "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-trafficked-underage-girls-for-sex
The Sex-Trafficking Model Scout
28
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 $100,000
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 more
Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova
from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to
trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein
"massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday
present"; and befriending Michael Wolff.
But as Conchita Sarnoff 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 Marcinkova
'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. Sarnoff 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
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 $1 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,
Sarnoff 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 visited 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" Lapina via an MC2
scoutina competition for young teens) and currently represents Vogue China covergirl Liu Dan.
Worldwide, MC2 represents such stars as Sessilee 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 "scouting
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 1970s 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
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 andJor 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" 13-year-olds from Eastern
Europe and (the NA, h iter parts of) 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?
http://nypost.com/2011/11/18/j effrey-epsteins-level-3-sex-offender-status-upheld-by-ny-appeal s-
court/
31
Jeffrey Epstein's Level 3 sex offender status
upheld by NY appeals court
By Dareh Gregorian
November 18, 20111 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
http://pagesix.com/2007/10/06/model-shop-denies-epstein-tie/
MODEL SHOP DENIES EPSTEIN TIE
By PageSix.com Staff- October 6, 2007 1 9:00am
THE 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 15. 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 1 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
http://www.palmbeachdailynews.cominews/news/lawsuit-doeuments-link-jeffrey-epstein-
to-modeling/nMGzHi
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 learned 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
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 18-month state sentence. He 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, Clinton flew several times on Epstein's
planes, many times with Maxwell, Palm Beach resident Sarah Kellen and Adriana Mucinska —
"all employees and/or co-conspirators of Epstein's," according to the court papers.
The documents show that Clinton flew with Epstein, "then suddenly stopped — raising the
suspicion that the friendship abruptly ended ...
"Epstein's personal phone directory from his computer contains 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, Doe 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://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned-
regulation-for-agencies-to-stop-child-sex-trafficking/
35
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 $100. 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), I learn about, it knocks me down, one more time.
Slavery
Debt Bondage
Sexual Slavery
Child Brides
Forced Labor
Child Soldiers
Adoption Trafficking
Organ Trqfficking
Trafficked Athletes
And now a new one I should have seen coming.
Those very young, foreign models you see? Some of them were trekked 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 trekkers; Go to politically or economically unstable areas;
locate 5'l1" 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 family anywhere in the
world and offer them this in return for absolute control.
All the 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
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
Conchita Samoll
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
37
prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or
anyone else who requests, Brunel is free to scout for very young girls without limitations." Given
his citizenship he also successfully avoided deposition in Epstein's sex related cases.
Like so many other reporters who have tried to report his side of the story when Jezebel
contacted Brunel, "he did not respond to our interview request." According to Jezebel:
we spoke to a number of people who worked with his agency and while MC2 isn't considered a
major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the
business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does
scouting for the agency and takes care of the international relations with other agencies, reports
one source. Scouts scour the world for unrepresented teenage girls who could make it as models.
They work largely unsupervised and are generally paid a headhunting fee for every girl an
agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts
operate mostly independently and with little oversight. The company blog refers to Brunel as a
'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting.
Model, Michael 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
Journaimagazine. 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
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
http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned-
regulation-for-agencies-to-stop-child-sex-trafficking/
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 $100. 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), I learn about , it knocks me down, one more time.
Slavery
Debt Bondage
Sexual Slavery
Child Brides
Forced Labor
Child Soldiers
Adoption Trafficking
Organ Trekking
Trqfficked 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 trqffickers; 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 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
trqfficked, 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 the traffickers have to do is pull out a magazine or phone with videos on it.
39
I'm not shocked at trqffickers using this method qfprornise.s 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
Conchita Samar
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
40
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 5'11" underage teenagers to work for his agency, MC2, or
anyone else who requests, Brunel is free to scout for very young girls without limitations." Given
his citizenship he also successfully avoided deposition in Epstein's sex related cases.
Like so many other reporters who have tried to report his side of the story when Jezebel
contacted Brunel, "he did not respond to our interview request." According to Jezebel:
we spoke to a number of people who worked with his agency and while MC2 isn't considered a
major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the
business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does
scouting for the agency and takes care of the international relations with other agencies, reports
one source. Scouts scour the world for unrepresented teenage girls who could make it as models.
They work largely unsupervised and are generally paid a headhunting fee for every girl an
agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts
operate mostly independently and with little oversight. The company blog refers to Brunel as a
'scouting tsunami' and MC2 is fairly well known for the strength of its international scouting.
Model, Michael 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
Journaimagazine. 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
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
http://files.wallstreetfolly.com/wordpress/2007/10/jeffrey-
epstein-doesnt-want-to-be-branded-as-a-sex-offender-for-
life-and-no-hes-not-a-m odeling-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
\
inerrelftECI
arty-Ham
Jeffrey Epstein, 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
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
http://www.washingtonpost.comincws/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-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.
Here are the important facts, taken from the 11th 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 Doe No. 1 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
On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 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 11 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 agreement was a possible remedy 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 review 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., 860 F.2d 844, 846 (8th
Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even jilt 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
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) ("111he 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. 1, 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. In 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
--------Original message--------
From: Jolanta MOD1LINOS
Date:15/10/2014 4:46 PM (GMT+02:00)
To: Jean Luc Brunel
Subject:
Dear Jean Luc,
Hope 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
Jolania Sadauskiene
owner
MODILINOS model agency MODILINOS models
Parodos 7-4, Kaunas Sv.Stepono 7, Vilnius
tellfax:+37037323257 cell:+37069816103
iolantaAmodilinos.coni Thfo4modilinos.corn
www.modilinos.corn
EXHIBIT B
From: "Vladimir Yudashkin © 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 internet 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
-------- 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
rn
MEGA
PARTNERS
MANUELA W MARTINEZ
International Relations
Phone: +5611 3818.4800
Direct: +55 11 3818.4827
Cell.: +5511 98668.0090
megainodelbrasil.corn.br
EXHIBIT D
Original Message-----
From: Lorraine <lorraine@mc2mm.com>
Organization: MC2 MM
Reply-To: <lorraine@mc2mm.com>
Date: Friday, August 27, 2010 at 8:49 PM
To: <jeff@mc2mm.com>, Jean Luc Brunel <jeanluc@mc2mm.com>, Pink
<pink@mc2mm.com>
Subject: FW: Press Inquiry from AFP (Agence France Presse)
Videographer--Michelle Stockman
-----Original Message-----
>From: Michelle STOCKMAN [mailto:Michelle.Stockman@afp.conn]
>Sent: Friday, August 27, 2010 11:03 AM
>To: lorraine@mc2mm.com
>Subject: Press Inquiry from AFP (Agence France Presse)
>Videographer--Michelle Stockman
>My name is Michelle Stockman and I am a video journalist for Agence France
>Presse, the French newswire. We produce 1.5 to 2 min. videos that are
>distributed internationally to broadcast clients in Europe and Asia, and
>Internet clients worldwide. In preparation for Fashion Week, my print
>colleague and I are interested in doing a piece on trends in casting
>models
>of color. I was wondering if you could refer me to a model of color and a
>casting director who can comment on her experience.
>My deadline is next week, so I would like to set something up for Monday
>or
>Tuesday. I can come to you as I am a one-person camera crew. When you
>have
>a moment, please let me know. I'd be happy to discuss with you over the
>phone ahead of time.
>Best regards,
>Michelle Stockman
>Michelle Stockman
>747 Third Avenue, 35th Floor
>New York, NY 10017
EXHIBIT E
>917-533-3261
>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
Sent from Samsung Mob.le
------ 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 all over the internet.
You need to have it stop and have the people write an official letter to say that it's not the truth...
I will keep you posted of course but it's really bad for us and the scouting.
Best regards
-
Michael Sanka
3104021028
EXHIBIT F
FOX
r sH infq GLCv
Ann: Scouting division MC2
We took notes of your comments and the girls that you like on our website.
We know Jean Luc Brunel and we always work with him since more than 10 years all
those years and never had any problems.
All the girls he represented from us never had any problems, they were working have
great book work with good clients in editorial and campaigns and were well represented
models.
Now for all the new faces we have, we needed to talk to their parents to discuss about
mc2 and you interest to represent their daughters and of course they google it and saw all
the had articles about sex trafficking they were scared and I was myself speechless since
we know that it's not true but it 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 everything, till then we will have 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 11000. Svetogorska 35 v. Stan 12
www.foxmodetcom
e-mail: foxaffice@sezampro.si
EXHIBIT G
Tel +381 11 3346414, tel +381 11 3226202
1 Q As 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
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
18 Q That means -- that means at any time no
19 model, no minor model came to you and said, you
20 know, "Maritza, look what just happened to me", that,
21
22
23
24 "I don't have a place to live". Or, "Look, I didn't
25 get my ticket", or whatever.
EXHIBIT H-1
Jean-Luc Burnel acted inappropriate with her?
or complaining about Mr. Brunel. Nothing.
"something bad happened to me".
A Maybe a model came and told me, "Maritza,
look what happen to me. I don't have any money," or
43
1 a--
2 MR. OBRONT: Well, I would object, because
3 of circumstances.
4 BY MR. DAVID:
5 Q But you said before that you never heard
6 anything that would indicate that Jean-Luc Burnel
7 behaved inappropriately with -- with any models,
q especially any minor models that MC Square may have
9 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 Q Right.
6 A And my answer was no. Nobody came to tell
7 me. I never saw. I never knew. His personal life
8 was not my problem.
Do you have any actual knowledge, that is
0 to say were you present or did you see with your own
1 eyes, any minor models go with Jean-Luc Burnel to
2 Jeffrey Epstein's home, or any party of his?
3 MR. OBRONT: Objection.
4 THE WITNESS: I'm sorry, but I take the
5 Fifth.
EXHIBIT H-2
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SUPPORTING DOCUMEPOS
EXHIBIT 1 Several press and media articles documenting the rise of South
Beach as one of the United Slates' main fashion capitols.
EXHIBIT 2 Press articles regarding the models and actresses who were both
discovered by and careers were launched by the beneficiary. Jean
Luc Brunei.
EXHIBIT 3 Several articles regarding the prestigious reputation of Kann tviadets
as formerty one of the world's leading agencies.
EXHIBIT 4 A list of all of tiAC2's clients, including several high-profile campaigns
featuring some of MC2's fashion models. as well as several press
clippings regarding this prestigious and reputable modeling agency.
EXHIBIT 5 The beneficiary's. Jean Luc Brunel. impressive curriculum vitae,
verifying his tremendous accomplishments in both the fashion and
modeling industries.
EXHIBIT 6 Several articles regarding the 2004 Models New Generation Contest
(including translations) as we as the beneficiary's leading role within
this prestigious modeling event.
EXHIBIT 7 Several press orlicles regarding the prestigious 2006 Models New
Generation Competition (including franslatiansl, as well as the
beneficiary's Jean Luc Brunel, leading role within Illt event.
EXHIBIT 8 Letter of Claudia tviiiaolo, President of Modetwork. a renowned
modeling agency.
EXHIBIT 9 Letter of Alia Amonlova. Director of Faro International
Management.
EXHIBIT 10 Several press articles reflecting the prestige and high circuiarian rates
of the mentioned mngazines and periodicals which have featured
and covered the modeling events which the beneficiary. Jean Luc
Brunel, hos Organized throughout the year.
EXHIBIT 11 Information regarding the extremely successful and prestigious
modeling and fashion association, International Model Taieni
Association (IMTA),
M C
NIODELSMIAtvil
July 25. 2014
Department of Homeland Security
United Stales Citizenship and Immigration Services
Vermont Service Center
30 Houghton Street
Saint Albans. VT 05478
RE: 1-129, Petition for a Nonimmigrant Worker
0-1 Extraordinary Ability as an Art Director and Talent Coordinator
Petitioner: MC2 Models Miami, U.0
Beneficiary: Jean-Luc Didier Henri-Rene BRUNEL
Dear Sir I Madam:
The present fetter and its enclosures are submitted in support of the
attached 0-1 petition of MC2 Models Miami. LIC, on behalf of Mr. Jean Luc
Brunel. The petition is based upon Mr. Brunel's standing as an "Alien of
Extraordinary Ability in Art Direction and Talent Coordination." Kindly note that
Mr. Brunel currently holds 0-1 status with our organization.
The South Florida area and Miami Beach in particular have become a
mecca for the fashion and modeling industries. As a result many of the largest
international modeling agencies such as Ford. Elite, and MC2 have opened
offices in South Beach and the area has become one of the most important in
the modeing industry In foci, Miami Beach has become second only to New
York City in terms of employment opportunities for fashion models in the United
States. Attached as EXHIBIT 1, please find several press and media articles
documenting the rise of South Beach as one of the United States' main fashion
capitals.
In 1996. our company, MC2 (formerly Karin Models}, established an office
in lhe heart of the historic Art Deco District of Miami Beach. "South Beach' has
truly become one of the world's modeling capitals and we are pleased to be a
Pcirf of il Our agency has developed a highly distinguished reputation in the
modeling industry. We specialize in representing numerous moaels of
infernailanal acclaim. Having discovered faces such as Christy Tixlington, and
molded the careers of celebrities such as Sharon Stone, Estella Warren. Milo
awe' mods maw- • 1674 Won mad • su)1e 640 • mialTh beacti I133134
Nab 672 6300 • fa: 305 531 8330 • adminostration 305 672 7672 • fax 345 672 6332
rric2trim
Jovovich. Jerry Hall and Rebecca Romiin who is currently starring in the award-
winning ABC television series. Ugty Betty; MC2 models are among the most
sought after in the industry, as evidenced by the caliber of their commercial and
editorial bookings. Many of our fashion models have graced the pages of
leading fashion magazines of the United States, Europe„ Latin AMeriCO. Africa.
and Australia such as Vogue. Teen Vogue. ale. W, Glamour. V. Mane Claire.
Surface and Cosmopolitan as well as many more throughout the world. In
addition to our Miami Beach office. MC2 Models has offices in New York City
and Tel Aviv. Israel.
As Artistic Director and Talent Coordinator tot MC2 Models Miami. (IC. Mr.
Brunet will be responsible for overseeing the artistic aspects of the agency. By
overseeing the art department in the agency. Mr. Brunel will direct the visuar
marketing of the models to clients. focusing on the images placed on both the
model's composite cards and their portfolios. Both of these marketing tools are
crucial in marketing fashion models to their appropriate catalog, editorial, or
media clients. As Artistic Director and Talent Coordinator, Mr. Brunei will also
,:oorciinate the pairing of fashion models with a particular photographer. Clients
for the agency include a myriad of fashion pubfications, retail stores, consumer
oracluct companies, and fashion houses lo name but a few. Recruitment of
talented artistic photographers who have an exceilent understanding ot the 'ins
and outs" of the modeling and fashion industry is cnbcal to the successful
running of a top-modeling agency such as MC2 Models. Mr. Brunel will also
continue with his amazing track record of discovering the world's greatest
talents and beauties in order to sign them with MC2 Moclet.. Mr. Brunel will
continue to travel around the works looking for new talents, and to agencies
around the world in order to establish relationships with those agencies and
allow MC2 Models Miami. Li.0 io represent them in the United Slates.
Mr. Bruners impressive Qualifications as an Art Director and Talent
Coordinator, establish eligibility as to the regulatory standards for such
classification as a top professional in his field. Mr. Brunel meets the 0-1 criteria as
an individual of extraordinary ability in the Arts and Entertainment field as well as
a business entrepreneur. MC2 Models Miami. 1,1C is presently seeking a
cophisticated art director and latent coordinator. After reviewing his experience
and accolades, we ore confident that the beneficiary, Mr. Jean Luc Brunel, will
perform said function with outstanding kiii and professionalism.
J. MR, BRUNEL'S QUALIFICATIONS AS TbE RENEFICIARY
In addition tc, Jean Luc Brunei's extensive business Qualifications, his
-weer as art individual with artistic vision and creative talents Qualifies him as an
0-1 alien in the Arts and Entertainment Field His all- encompassinin experience
as art Art D'ector, Talent Coordinator. international entrepreneuo and business
leader in the modeling, fashion, entertainment, public relations, restaurant. and
tourism industries has made Mr. Brunel internationally renowned in Those fields.
Among his various accomplishments throughout his career are the successful
modeling agencies he has founded both in Europe and in the United States. For
example. in 1978. Mr. Brunel founded and grew Karin 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 Karin
Models as a platform for marquee clients to obtain sophisticated public relations
services and important modeling contract opportunities. Mr. BruneI's success
was so great with Karin Paris that in the next ten years. he founded Next Model
Management in Los Angeles. California in 1980. Next Model Management in
Miami, Florida in 1982, Mode/ Management Group also in Miami. Florida in 1966.
and Rebecca Commercial Casting in New York City. in 1988. The loiter one was
opened as a talent and casting agency for performers. offering services such as
voice-overs, television, and cinema advertising work. again. successfully carving
out a 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
in 1989, who partnered with Joel Wilkenfelcl a couple of years later; NEXT
represents some of the most prestigious women and men in the fashion world
today. Star talent includes renowned fashion models Molly Sims, Daniela
Pesiova. Audrey Quock. Yamila Diaz. and Malgosia Bela. NEXT continues to
maintain an influential international force in the fashion and modehng industry
through its fully operational offices in New York. Los Angeles, Miami. Sao Paolo,
Montreal, Landon. and Paris, as well as its affiliates in Milan and Australia.
Because of strong revenue growih and successful business performance.
as a result of his ariislic vision as an artistic director and talent coordinator. Mr.
Brunel founded the very successful Karin Models of America in New York City
and Karin Models USA in Miami Beach. Mr. Bruners commercial ventures in
opening Karin agencies in Paris. New York. and Miami have been extremely
successful, generating combined annual revenues of twenty five (25) milion
dollars. Eventually, Mr. Brunel hcensed the Karin name to agencies In Israel,
Denmark. Germany. and Spain. Mr. Bruners extraordinary talents are not only
limited to launching successful modeling businesses. but also in discovering and
launching the careers of some of the world's most successful models. Mr. Brunel
has launched the extremely successful careers of supermodels such as Christy
Turtingion. Rachel Hunter, Sharon Stone. Monica Bellucci, Estella Warren, and
Christina Semonnovskaya. These women all proceeded to become some of the
most photographed international cover models in the world, appearing on
Thousands of magazine covers woirictwide and spanning many years. As a result
of his reputation as a highly visible, strategic networker who cultivates and
conducts business in a global environment and bookers lucrative cleats, mory
lop players in the fashion and entertainment field requested that Mr. Brunel
function as their exclusive agent and representative. Some of these top former
and present professional supermociels in the fashion field include. Naomi
Campbell. Christy Turiington. Rebecca Romijn, Mia Jovanovich, Inez Sastre,
Melanie Thierry. and Jerry Hall. Attached as EXHIBIT 2, please find press articles
regarding the models and actresses who were both discovered by and careers
were launched by the beneficiary. Jean Luc Brunel. Additionally, attached as
EXHIBIT 3, please find several articles regarding the prestigious reputation of
Karin Models as formerly one of the world's leading agencies.
Most recently in October 2005. and after his reign with Karin Models, Mr.
Brunel launched the prestigious MC2 Model Management worldwide with
offices in New York. Miami and Tel Aviv. Mr. Brunel storied the high-profile MC2
Model Management in order to represent high fashion models in a boutique
agency setting. MC2 Model Management is already being lauded by fashion
insiders as "one of ihe hottest agencies in North America" as well 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.m_c2rnm.cpm in order to view the high-caliber of models. MC2
represents Some of Hs most recent successful bookings include Liu Dan'',
exclusive contract as the face of the Fall 2007 Guess Campaign and Sammy
Jo's cover story for Cosmopolitan Magazine. Attached as EXHIBIT 4, please find
a list of all of MC2's clients, including several high-profile campaigns featuring
some of MC2's fashion modes, as well as several press clippings regarding this
prestigious and reputable modeling agency.
Jean Luc Bruners entrepreneurial spirit is not only contained to the field of
arts, beauty. and fashion. In 1970. as a result of his business insight, Mr. Brunel
founded and grew Jean Luc Relations Public:we, which specialized in press and
promotions for tour operators and restaurants in France. During his work through
Jean Luc Relation) Public:we. Mr. Brunel represented various key clients and
collaborated on numerous prestigious events. Some of the prestigious events
include.. Air Tour and Daro Voyages. Jean Luc Relations Fubliaue also promoted
and marketed La Tour D'Argent, a three-star restaurant owned by Claude Terrait
and. "The Go-Between", a motion picture by George Losey. Other projects
token on by Mr. Brunei through his public relations company was his work as
product agent for Jean Claude Kitty. 1968 Winter Olympic Gold Medalist skier, to
promote Vail. Colorado in France for tourism potential arid also directed all of
the promotion for Finland's Ministry of Tourism. In 1975, Mn Brunel further invested
in the Food and Hospitality market by creating and developing "El Mono
Desnudo"- a legendary, high-end bar on the Iberian Peninsula. This bar was
known throughout the peninsula as extremely exclusive and attracted a
celebrity clientele that included actress, Ursula Andress, and lhe Duchess
D'Alba. Attached as EXHIBIT S. please find the beneficiary's. Jean Luc Brunel.
impfessive curriculum vitae. verifying his tremendous accomplishments in both
the fashion arid modeling industries.
II. ELIGIBILITY FOR CLASSIFICATION AS AN ALIEN OF EXTRAORDINARY ABILITY
THE ARTS
Under the Miscellaneous and Technical immigration and Nationality
Amendments of 1991, petitions for classification as an Alien of Extraordinary
Ability in the Arts must be supported by evidence of "distinction". According to 8
CFR §214.2(o) (Mil), "distinction" 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 extent that a person described as prominent
Is renowned, leading, or well-known In the fields of arts, This evidence may
consist of proof that the alien must be recognized as being prominent in his field
ot endeavor as demonstrated by the following according to 8 CFR
§214.2(0)(3) (iv):
A. Evidence that the 05en has been nominated for or has been the recipient
of significant national or inlernational awards or prizes in the particular field such
as an Academy Award, an Emmy, a Grammy. Of a Director's Guild Award, or
B. 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 as evidenced by critical reviews, advertisements,
publicity releases, publications contracts, or endorsements;
(2) Evidence that the alien has achieved national or International
recognition for achievements evidenced by critical reviews or other
published materials by or about the Individual in major newspapers. trade
journals, magazines, or other publications:
(3) Evidence that the alien has performed, and will perform, In a lead,
starring, or critical role for organizations and establishments that have a
distinguished reputation evidenced by articles in newspapers, trade
,journals, publications, or testimonials:
(4) Evidence that the alien has 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 publication'',
(5) Evidence that the alien has received significant recogntHon for
achievements from organizations, critics, government agencies, or other
recognized experts In the field in which the alters Is engaged. 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)(1v) 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 $VBSECT1ON 0
The afg_mitng that the beneficiary satisfies is gl CPR 4214,2foX3IfirOf8)(1),
which requires 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 as evidenced by critical reviews, advertisements,
publicity releases, publication contracts, or endorsements.
As a result of Mr. Brunei's combined expertise in fashion and tourism, he
decided to create Latin Model Pageants, now known as Models New
Generation- to cross promote these key industries with international business and
investment opportunities. Mr. Brunel has promoted and judged various modeling
contests throughout South America including modeling contests staged in
countries such as Peru. Ecuador, Brazil, Argentina. and Chile. Conceived in 1987,
the Latin Model of the World event was a high-end modeling and entertainment
product that appealed to upscale international audiences. reaching nearly 400-
million television viewers worldwide. Throughout his history as a major
infernalionai event promoter and artistic and talent co-ordinator, Mr. Brunel has
orchestrated multi-faceted public relations. advertising and media campaigns
that incorporated television, magazines, programs. newsletters, and promotions.
becoming notably lucrative for various major brands as a promotional tool. Mr.
Bruners acute knowledge of marketing and promoting skills has turned his
various international events into highly successful artistic and business ventures
tar various major brands Latin Model Pageants attracted major brands as
sponsors, such as American AfrOnes, Ray-Ban, Coca-Cola, Proctor & Gamble.
and Revlon.
Mr. Brunei's has continued his ventures as both a promoter and panel
judge when he founded and created the international modeling contest,
Models New Generation !hat took place in Guayaquil, Ecuador in 2004. Mr.
Brunei sat on a panel with three other professionals in the fashion industry and
judged over forty-nine young women from over North and South America. Asia,
and Europe. After len days of harsh competition, Jean Luc Brunel crowned the
winner, Alyne Weber. a fifteen year old from Brazil, whom as a result of coming in
lust place was awarded over three hundred thousand dollars worth of modeling
contracts. The city of Guayaquil. Ecuador was also thrown into the international
spotlight as the host city for the modeling contest. The Models New Generation
was broadcasted on numerous television network channels including. Fashion
TV, which transmits to over 202 countries throughout the globe, the entire
Association of Television Channels in Ecuador, National Television of China, and
Recle Globo. Brazil's largest and most popular television network. Attached as
EXHIBIT 6, please find several articles regarding the 2004 Models New
Generation Contest as well as the beneficiary's leading role within this
prestigious modeling event.
As a result of the tremendous success of the first Models New Generation
that look place in Guayaquil. Ecuador in 2004, Mr. Brunel organized the second
Model New Generation Contest which was held in 2006 in the Ecuadorian
capitol of Quito. In order to select only the very best new models, several
Preliminary. qualifying shows were held in different countries of Latin America
including Bolivia. Panama and Peru. The final conies: was held in Quito, Ecuador
at the historical Plaza San Francisco. Mr Brunel sot on a panel with three other
professionals in the fashion industry and judged over forty-eight young women
iron' twenty-eight different countries from North and South America. Asia, and
Europe. After ten days of harsh competition, Jean Luc Brunel crowned the
winner. Gird° Lapina, an eighteen year-old. from Latvia, whom as a result of
coming in first place was awarded over three hundreo thousand dollars worth of
modeling contracts.
The city ot Quito. Ecuador was also thrown into the international spotlight
as the host city for the modeling contest. Again. just like the immense media
exposure given to the first Models New Generation competition of 2004, the
2006 Models New Generation competition was broadcast on numerous
television network channels including, Fashion TV. which transmits to over 202
different countries throughout the globe, the entire Association of Television
Channeh, in Ecuador, National Television of China. and Rede Globo. Brazil's
largest and most popular tetevision network. Attached as EXHIBIT 7, please find
several press articles regarding the prestigious 2006 Models New Generation
Competition, as wel as the beneficiary's Jean Luc Brunel. leading role within the
event. The 2006 Models New Generation program was broadcast in over 202
countries throughout the world. Mr. Brunel has performed and will most definitely
continue to perform services as a leading participant in modeling events, which
have a distinguished reputation and wilt bring more public international light to
MC2 Models.
For the above-rnentinneOr.m.r1,ns,, 131uriel Satisfies INA §214.2(a)(3)tivi (B1( I ).
The second prong that the beneficiary satisfies is 8 SJI
fa14,2(03)fiv)fBn. which requires evidence that the alien has achieved
national or International recognition for achievements evidenced by critical
reviews or other pubtisned materials by or about the Indlvidvol In major
newspapers, trade journals, magazines, or other pubecations.
Mr. Brunel holds an international reputation as ci visible. strategic
rietworket who is able to cultivate expert relationship management skills in cider
to conduct business in a global environment and broker lucrative deals. Mr.
Brunel has a long history in marketing and advertising maim fashion campaigns.
throughout his twenty-five year career in the fashion business, Mr. Brunel has
developed vvotidwide exclusive modeing and cosmetic campaigns. Some of
these major cosmetic campaigi% include: Bio Therm with supermadel Etle
McPhersor., PeAS with Rebecca Rornijn, Christian Dior with Christina
Semonnovskaya. Margret Astor with Monica Bellucci. Chanel with Patricia Von
Rickenheim. Angel Perfume with Thierry Mugler. and Cacharei Perfume with
Aida BaHestia. Mr. Brunet has also developed major fashion campaigns and has
developed campaigns and exclusive contracts with some of the waticrs top
fashion designers such as Yves Saint Laurent. Chanel. Christian Dior. Gucci,
Nada and Marc Jacobs Please see the enclosed letter of Claudia fvtidolo,
President of Moctetwork, a renowned modeling agency. EXHIBIT B.
As a talent coordinator, Mr Brunei's success can arid should also be
measured with me 3ucce55fu1 careers the models. whose careers he launched.
have achieved As slated above. Mr Brunel has discovered and represented
various ruper models throughout his career. Christy Turlington. who was
discovered by Mr. Brunel, has personified unaffected beauty- representing
Calvin Klein's fragrances since 1987 Turtington. as well as another model
represented by Mr Br unel. Naomi Campbell, becarnt- one of the few
superrnocie6, who managed to make on easy transition from the haute glamor
of th 19BO's to the relaxed simplicity of the following decade. Throughout hei
extensive career, arid as a result of Mr. Brunet's "Fashioii- Savvy Eye", Christy
Turiington tio graced the cover of hundreds of fashion magazines. surf*, as
Casmopotital ,, W. vogue, Shape, Fitness, Elle. Bazaar. mcirie Claire. Harpers.
Esquire, and even Time Magazine. Please see the enclosed letter of Alla
Amantova, Director of Figaro International Management. EXHIBIT 9.
In (addition. the modeling events that Mt. Brunel has been organizing
throughout the years receive not only national, but also international attention
and appear in multiple publications around the world. One of the most recent
events he organized. the Models New Generation contest, which took place in
Ecuador was publicized and transmitted by various television networks and
appeared on multiple newspapers and magazines, among them Globo
Television Networks in Brazil. Fashion TV which is broadcast into 202 countries
throughout the world, El Univers°, Cows, La Razon, El Diario. El Telegrafo.
Notinorfe, Extra. Hoy. El Gran Guayaquil El Comercio. Semana. and 8 Lideres. to
name a few. These major publications have a large subscription rote which
numbers in the many millions of readers. Attached as EXHIBIT 10, please find
several press articles reflecting the prestige and high circulation rates of the
above-mentioned magazines and periodicals which have featured and
covered the modefing events in which the beneficiary. Jean Luc Brunel. has
organized throughout the years.
Hence the beneficiary satisfies NA §214.2{031(iv)(13)(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 third prong that the beneficiary satisfies is 8 CFR 4214.26,1(310001f4),
which requires evidence that the alien has 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 of the main reasons that Mr. Brunel has been able to not only survive,
but also be extremely successful in the ever-changing world of fashion is his
ability to identify and recruit star-quality talent, As a result of his ability to scout
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 Talent
Association (hereinafter IMTA). The MIA is an international association of training
centers for models and talent. IMTA gives aspiring models. actors, singers. and
dancers spectacular opportunities to showcase their potential talents in front of
too fashion and talent agents from the major 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 world.
Several of todays up and corning actors arid models have been discovered at
IMTA; some of these discoveries include world-renowned actors such as. Elijah
Woods, Ashton Kutcher, Katie Holmes, Eva Longoria. Jessica Biel, and Sean
William Scott, Attached as EXHIBIT 11, please find information regarding the
extremely successful and prestigious modeling and fashion association, IMTA.
Additionally, please find several pages from IMTA's official website documenting
their discovery of the above-mentioned Mist actors and actresses, whose
membership in IMTA proved to be the launching pad for very successful and
highly profitable careers in the film industry.
Furthermore, as previously mentioned. Mr. Brunei has launched the
successful careers of many internationally renowned models, who have been
featured and still are in many international and nalional fashion magazines. In
addition, his commercial ventures. especially MC2 Models. formerly Karin
Models, have been extremely successful generating combined annual revenues
of twenty live 125) million dollars. Currently MC2 is one of the most successful and
well-known modeling agencies in the world. Mr. Brunel is one of few people in
the modeling business that have achieved a similar standing and have been
able to maintain it for over twenty-five years.
For the above-mentioned reasons, Mr. Brunel satisfies INA §2144.2(o)(3)fiv)(8)(4).
EVIDENCE THAT THE BENEFICIARY MEETS 8 CFR B2141(01f3IfIv)fC)
The petitioner has submitted a plethora of evidence regarding Mr. Bruners
experience in the fashion modeling industry. Mr. Bruners has established MC2
Models, formerly Karin Models, which is presently one of the major international
modeling agencies. with combined annual revenues of twenty five miDion
dollars. Only someone with Mr. Brunei's expertise and strong strive for success
can achieve such international acclamation in the industry and been able to
maintain his status for over twenty-five years. Mr. Brunel is the one responsible for
the launch of numerous supermodels' careers, which hove been maintained in
the spotlight for several years. He has worked with renowned fashion designers
and photographers, who have trusted his work and intuition. In addition, Mr.
Brunel has orchestrated many international and national successful fashion
events that have received international acclamation.
For the above-mentioned reasons, Mr. Brunel in addition to meeting at least
three of the criteria of 8 CFR §214.2(0)(3){1v)(8). he also qualifies under 8 CFR
§214.2(0)13)(1v)(C)
Ill. CONCLUSION
It is clear from the evidence that Mr. Brunel is eligible for classification as
Lin Alien of Extraordinary Ability in An Direction and Talent Coordination based
upon his meeting the eligibility requirements under the Immigration and
Naturalization Act 101(a)(15)(0)(1) and 8 CFR 2)4.2(o). Mr. Brunei's successful
career proves that he is a prominent. leading. and well-known person in the field
of arts. Mr. Brunel's extraordinary ability in the field of arts, in which he witl
continue to work in the United States, has 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 classification as an Allen of Extraordinary AbIlity in
Art Direction and Talent Coordination. Again, kindly hate that the beneifciary,
Mr. Jean Luc Srunei, has held 0-i status In the past
Wherefore, for the above-stated reasons, we respectfully request your
favorable adjudication of the 0-1 nonimmigrant visa petition submitted by MC2
Models Miami. LLC on behalf of Mr. Brunel. If you should have any questions or
requie any additional documentation, please do not hesitate to contact our
office.
Thank you very much for your kind attention regarding this matter.
Truly Yours.
Mien. September Os, sou"
USW
Vermont Semler Outer
75 Lower Weide° Street
Bt. Album:4Yr osen-000i
BE 0-i Non-immignint V Maine on iwitalf al Jean We Dither
Henri•Itene Brunel
I write this letter in t.trong sup;x,rt of Mr. Jean LUC Bruner:, applicAton for
A non-inunigrard Visa to this oountry. I am currently Aninalnistratorr
Unice, In Studio Pp. I ha,,x: been asked to review the professional
credentials of Ma Brunei, and it i5 my profest,ional opinion that Ms. Brunel
is an Art Director and Tak-nt Coordinator of ettinerdibary ability who
ranks among the mnIIparentage of foreign people at 'red. top oaks field.
I have seen first-hand Mr. Jean Wes special expertise in the field.
intbding entity. production. coordination. and art direction for shoota.
Ur. Brunel is considered by those in our Wintry to bean extraordinary
creative director talent, particularly for the fashion and related indostrie:i.
In zny personal dealings with Mr. Jean Luc Brunel, I found him to he
thoroughly professional and capable of being utilised in connection with a
wide range of creative subject matter on any ainivinient. He has liw
intuitive ability to provide just what's needed in connection with any
particular cmtive process and possesses excellent artkic ossmuternent
and operational skills that come from his years of experience.
Many people do not understand that behind every IncOessfut ad‘ertis.ing
campaign and fashion shoot there are creative wen and wants who are
making sure that the business operates efficiently by coordinating different
tasks between models, photographers, and managing avative team. I can
honestly say that Mr. Brunei continually prom, himself as an
extraordinary talent its his field,
offer an unmitigated endorsement for Mr. Jean the Brtinet regarding his.
dart application asi a person of extraordinary ability. Th'pre is no doubt in
my mind that his popularity and ability in the field will only =time to
prç,per in pears to come
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Cad to tirdieein tiw ontotrustiolo of r>thfir i...nnftwgctiati m $hp fedd I have born *Ord 10
MOW fiiit protest:tom! ciredeestiahi of Mr. sky:,,r, Luc ersoet It be y prokoluGnitS optnirn,
lootd upon toy petwof and prolenotootolI linooloollse of *. amulet* udentri, that Vir.
Wood re en oft director of ceirrievainary Who* who ranks among tht. ormeil rarceltimp of
keeign ptrAteitatugeatwore top alma that
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perms_ ithadmi biy the Pugh !walk IllaterSIM et :ht comperises with *twit he reiguirf%
• thearb S am wail the cvnl; oar who *wettable his Woo, Hi* rttotirlst!furty appc4ied
an my tit die' weld* most pup4itpublicetione. eriacheig Ikterony uaierre er adounes
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medsikothoes Sc soktai stools. ouch oh itkiteld IOWA. 011014. Moe' New lietvrid
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thoormotthos for has wit. lie to weft worth the met
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moortsoriatiol isalaaverawral strict eckeoeigidirrurt-ri Should you hew ow ILrlitv,ril
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warichyklit fashion fidnan). I an the hodaction Manager at Ong Kids] Wok* and brig witted
vetth attth climbs as vogue' refthat. Nurnin), hatertarito, Yam GdfaIwit, IrtSrgfri and Allure
Atm Lac Brun& hie bsonnis inervatittgly well imam tit ow ISM as taatrlibedIe Iyho we' Web
manor raid direct Lathilxi trod& for clients, phottgraphers, ate. Mt. Jenn asc Elmo} aimh mined
ere to mixt th 11Xlid appzopriatz models to be Used in an axivetrritaus Calapagit, awl stersecroeney has
the otitatandkg ability in manage at stages ci thr- eteripirar wean of prodischrts tbe right model fm a
job_ Themfore, the quality n(bl wIt14 is II-Till:Able es lie is able to IthermoCt beaudioul Mad& As a
mak he fag becoming one of th,7. pi:kelt:amain cif choice bathe lambkin sod other CtlIltife
i =hart:ries.
Is my opinkin, Nes Lax Mast is eensty an indhitILIS3 of tatimordinary abiliV in the BM of am and
the warilian he will irteurne La the United States cleamiy requites an. indiAridual r x1raordina.-7 abdity tn
this tut& )ix, Brunel has %en homistialudiir hsicsra mad recogrited for' his larkftle Wait sad
esportise.t rfloanis be tines repdady *mann* tietb. rnoet rtestisbus faehinn uMkfr roubd
des worW nth lb nit Magaritir Glenicipoitfun, Nantabsta. Wt. Bruntre amtriimatiaws to
major cIin htive sexured hoz a pm-Iliac as ens uf the lesikug dirsobars And tam coordimidars
working tad* it is tirm my opinu-all that tbie zesprgirietris and Aut:irs of an internal:ins:31 it cErcetztr,
vrbo entiabeiratee with tilt mot distingualied truigazents and attkr.-Vairtg isiLesica, loquire an tnanrici.m)
afardy aff ability and aeocurrpl:shnteeits in tri Mr, Jess Lis Thritr,c1,
risatiaind an 04 "bats mortis the Vilna &ate% dais lac bond Ina nu* brim hia pberiamansi
talent Araeritsa =rim&
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VICO
Vermont Service Ciotti
n Lower Walden Strain
Albans, VT 064N-0001
REI 0-iiion-immignsu Visa Petition on belied? of Jests Luc Bros*
Dm Mem Madam
-
Sty name is Nadia Coma sad I am President of Wenger Ntreieh.l I bow
30 YVarS assporience sod lam CuihrWIt t. ia contact with profiesiorials all
over do world. A few al my clients in, Niir Elie klagszioe, MI110111.
Mow* !aura 3tiap. ugil. v'k.. The Eta, Stsrm. , sod so OIL Aim 4116, I
am qualified to comment on Mr. JIM law Brunei's caner as an of
direetor of ectracedinisr- ability
It is Dot only became of his &demotions or We impenritio body Of work
that fashion sdisstisisig sod publishing executives mold the world
I..a . choestie O M hm . Brunel's great talent lot their renowned aCCOM Mr.
4lion Luc Brawl is idea an pi300411t0 Imen at furnishing bit chest with
tautly dui image of their dram. My perwr.al appreciation of Mr. : ruse!
who is saw for ow to r-rJrvrwl his acciarriatians. F'rurn my
sgeridtgailte they are certainly !sell coofirmsd. Accordinciv, Mr Brund bill
a position to conanrad sizable conipanastion for his wars as comperes to
obits in the Winos
M. inuesrs minas:Fa as a tartaidabie artist with a personable demeanor
precede, him tia is ositstantly ressarchiannO dirreloping stimuistingly
now commis for his clients and I bine mine to rily on end tnot Mtn and
his ability. OM the tt.n.:rbv. ha celebrated career. Jraft Lar Brullel
diginguished himself es oar of SE leading fashion an director in the
industry.
Kt AIM Lae ilinasi enjoys an extraordias Ft. IlltatiOnSteiri to the acittstw,
This gadfly manifests Itself through the besutiful work hr createN. Wee
Id* time. Therefore. Jan We Brunei la dauy ens f tiw MOO tabard
professionals working is the worki today I look forward to seeing rn.,re' of
his work in the future.
Sintaisty'goara,
4/64tee-C-t.."
Nadia '.sotfrys
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USCIR
Vow* Sono, Coles
73 Lower Walden elms
AllAnikeVr 0947114X101
RE- 0.1 titten.inursgrani ,a.a Patton on being of Alan Luc (Mod
Omer tieovMsir
1 would Mei* Wend req tifil end unqualified support for the OXIMONlinelY gtatV 04 Wes
POW INAMIted b tAz Jaen LW ate* ea the Oen* reknit Produces fee
tiortalrorn, I ent quailed to ley that M. Jean Leo Dural It 01 art ditoint ocl Want
feted11.21 of the highest caber whose Wyk* emotional end creed* *ice how
NNW tots fav no hie prafeeelen
Ilmoughote Mt Man ILuc emigre detinguilluei career, he hoe recov, ad a lughti
ininnsolvo let of woresstangs POWS end 10ch1evonantli Ni grilk Pelt WO WM riff
efamill ties atm kid beautiful citadels that haw appearod ins bat =tanned oraffir.ls in
seeta efts nod enthont publicatkina in the Iti. v4110 saves as a tounant ha
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I ant e awoke' wens* to the ezaaiwo and operational skits of many cmvo wean"
puck loniuding art direness and Want coonlInelora, ft la Virsloni irg plenum so
risoogolvs Ternentable talon sect achievements of Mr. Jeer Lug lir uml. Hs OVUM
ito etal lave I* Amp* mai* from the meet cared" deveiopod creatconcepts and
idea I Is hie very unique ability to COMIrruicalsk, via award anal**. WM intended
altiee hump of his chants, II is ober that Pk demi LW erlitid*I*41011C1 far beyond
evii swami levels lor SUS inetistly by S Wunrili15 Mt% loth lahtili 11* Voprit
considanel. Indeed he has worxedsiSi sone of 111710 beit4UVAVII ATM, %Wrt o
house.. end eisquinee vt wade; is tr. maw tio.obt met 1 polo 1071 the c'erika
111a vvey bad Is fda prolgastan
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Recommendation Lmter
22/09/
USCIS
Vermont Sew= Center
75 Lower WeIdea Street
St. /dhows. VT 05479-0001
RE: 0-1 Non-immigrant Visa Petition on behalf of Jean Luc Brunel
Dear Sir or Madam:
It is an extreme pleasure to write a letter of recommendation for Mr. Jean
Luc Brunel. I provide this recommendation based on my knowledgr and
experience in the field of modling, due to my established reputation and
work in the field as the Vladimir Yudashkin, director of I Mother Agency.
Kiev. Ukraine
I have known Jean Luc Brunel pmfeanongilly for 5everr4 years thmugh
our wink together and, in my opinion, he is an ext*mely talented
Individual with superb profettsional reputation. He is an !extraordinarily
able coordinator who strives for and attains a level of merit in his wnrk
that only a few of his contemporaries meet. He has the abilit3. to
recognize the creative vision of his client within the time and budget
through hbi careful and thoughtful choice, of model casting combined
imktig his meticulous ability in the field. Jean Luc Brunel is a true find to
our indusuy.
Mere are plenty of or, directors out there, but none with: the depth and
quality that Mr. Dninel possesses He is unlike anyone in this industry.
sod I expect to see him continue to find great models in his successful
career. Someone overflowing with talent as Jean Luc Brine] 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 tv contact me should you he :any questions
regarding Ohs matter. Thank you for ynur time and:r6nsideration.
'A.
Sincerely,
Vladimir Yudash
FIG010
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MODELWEIK
„IONA. It 14 faiklbil
`. (I P liv!
rii: 11 V% • 1-40-40-14L--
HrbxgBJLy. 2011
DePartment of Homeland Security
United Stales Cibzeriship and IrrmigRrion Services
Vermont Service Cer
30 ri,c•Jghtor Screer
AlbOnS. sir 05478
Re: 0-1 Extraordinary At.iily OS Om Ar- Dircc 4 Or and "alert CQ,crchnotcr
behdf of Jear-Li.c Didier .4enn-Renc Brunei
To Whom rt
AS 0 President .7f Niv_;.c-crk. Mil) *Her submitted in support at rAC2
MOdets Miami, _LC or behalf or Mr Jean Luc Brunel -o work as a* Art
Director and gaient Cpowatinotc,.
M. &tonal okj jii irtVrTatiOr rc.LIpiftl1i0M, as 0 w;ibio, shategit
networker who "-k able -o cultivate expert relationshio management sk tf.s
order to conducy tautness in a global ervirorwreng and &inter tucrarive
deals. Mr. Brunel nas a long nit2r,, marketrig and adiertic;ng craw
fashion campaigns. Inrougtio-it INT twenftf-tive year coreertinn trie fair vi
business. Mr. Brune' has developed worcide. exc.usive odelircj
COIMOliC campaigns. Some of 1-pese 'rtaior cowneTic campo'cn$
60 Therm iNitrl sugierrnader toe A..i..-,wrierw.n. t'HA5 VAM kebecca 11017,17-..
CNIStiOri 0101 g'ith Christina Ser........ftrwi(a.?a xitr.Tet Asia! with Mora
Belucci, Chanel wylti oirk i VcIf. Ar;., Perf.yjcie
mugoor. and CoUc Pertune - P4116010 . s has
developed rnaior fashiar, -L:rn-,..)trT3r onct rIfiS Oe., r.pecl cOrnpaigrti Ird:1
elitChnitle cc -mac is r5i the wø tap'5 deSiOr+E.,5 t• 4-h in%
Yves Sole aufent. Ctv Chro-4 Dior. GL:c:
JOCOlu.
In addilion to Mr. Jean Luc brunel cecensive business
career os an 4f1CitvAUCli with artistic vision ono crealpve to
turn find top fashion models to remesent ir tho United Slat
Shmde yap have any questor °boy' tioli ;ear BfL
tee tree to corlact rr-c,
4-1 s
iy4`
rq ci It
Prukffl
100
Modehidert. MotiLaiattenlin t
a. •Inc; M arc
atitiaatinnc, iii
rits has helped
MC3011 L Pr" OP •
DOWITOknl Of Mamba= SOCurlPy
United States Olitenerip and lierricration Sertioes
VernOnfService Can*
4ouoni0n Street
Saint Atm% Sef OSSIS
Re; 0-1 bdroordinary Mils as an NI Dec) and Tasont Coolrinatof on
behalf ar lean•Iluc Dicsev Iriend.Rene Brunel
vinlam maw Concern:
As a Proildent of Natalie Model Management. The letter is t..orritteci in
surrOart of han models mharTt C. on behalf of Mi. Joon Lt.ic MAW tiC
work as an kr Director and IOW Coordnufou
Stuns( hoot on interno"onot reputaflon 01 via*. silrotegiC
rsenvalter solo Is We to culfkalle expert retallaswiip rnanapernent sials
alderto candUct business in a global soviarvneni and broker liJaarrest
deals. hir. Brunet has a tong history in rnartotft and adveers,r9 fricVcc
carossceons Throughouttik inienly-ave yew career in .the fashion
bsilianO14, Mr. &Wei has devolopod worilwida. 110C4filve.:Zilireg end
covnetic compotes. Sarre 01i these molar =Work rr Includs4
Rio Them w4Wt supentiodel Ele mcfnerscr_ Pi4AS nth Rebeoco Ron*.
Ovidian olor %Intl Civisfina SOITXXvIOOkato. Marcel Airor welt] Monica
kW* Civonel Min PaillititlVanhiletenheke. An Peffunlewith Merl
Mogkze. and Cacharei Perfume vtith Aldo Bollestia.Mr. Wel hat also
artrelaped magi, fashion campaigns and not developed campaigns and
iseciudve Catteocis wilt) some of the *NOW, fOO kehiart (*honors PJCh 05
Yves Sarni tautest. Chanel. Chtistion Dior Gucci, Prada. ;and 'AOC
.00:001.
.3R9Prit1r2, WAIN a' wourtgaroa -4% .:J/1 133riav 11011
Iltr Ert Pi 1 Jti. • 1 lJ J41,11111, pasta nadriallitapplaalr.
fleg "‘it- PARLIQ5 uxis PSOAIVII -WO •J'APJ XIDG 810
es Walton to M. Jtar. Luc lituner's extensive &Anew wul kaftam.
Meet as on individt.id with °diet AMA and creative latent hat helped
hirn 11nd to models '12 woment in the tinied Slates.
MOW yeu have any quesions about , *on Luc bunsl luatriiccitions
teal free to contact me.
SirtrAtitv.
Erik Melsons
Mem. September re. 2014
USW
vermoot Service Cente,,r
75 Lower welder, street
St. Albans, Vr osetkosetot
RE 0-a Non-immigrant Mae Prtitloo on Wolf of Jean Lac Didier
Henri-Ilene Brunel
I write this letter in strong support of Mr. Ann Lae Droners applieaton for
non-immigrant Visa to this country. I VII currently iiiitittilnIstraitore
Unica in Studio It. I have been asked to review the prufeqz,lonal
credential; of Ma Brunel, and it is my professional opiniori that Ma Brunet
is an Mt Director and Talent Coordinator of eltreOrdinary ability who
ranks among the small percentage of !amigo people at yeti top of his field.
I have gnu first-hand Mr. Jean Lue's special exper;ise in the
including casting. production, comdinatinn, and art direction for &Gott
Mr. Brunel is ecnsidered by those its our industry to helan extraordinary
creative director talent, particularly for the (add= and related
In my personal dealings with Mr. Jean toe Brunel, I found him to be
thoroughly pmfe.ssional aid capable of being utilised in connection with.
wide range of crestive .aibietl matter on any itailatin$erit. He has the
intuitive ability to provide just what's needed In esortTection with any
particular creative prom-,3 and possees excellent tic management
and operational skills that toner from bis years of experience_
Many people do riot understand that behind MT, sneressful advertising
campaign and fashion shoot there me emative men and women who ate
making sure that the bvsmess operates efficiently by *Do tdi n 3ti ng different
tasks between models. photographers. and managing croative teams. I can
honestly say that Mr. Brunel oanlinclaly Roves, himself as an
extraordinary Went in hi., field.
I offer an unmitigated endorsement for Mr. JIMA Luc Brimel regarding his
Visa application as a ixtoon of extraordinary ability. Th'ere is no doubt in
my mind that Ma popularity and ability in the field will aid, continue to
p per In .ielrs to come
reb'' L. !.!
ler . 1.1 :" 5115
gi lib/ le
IJ5C18
Venni:int *mai Cantu
7$ Lower Welders Street
sie. Mows, VT 054'79-000i
RIL 0.1 NOrloalseriagreast Vise Prhtaisrs bet-os!: tit Joan
Oeir the ere adorn
I wee due tilt" se sums support at Ur Aeon Lie Brunets 4tiplickrion So a non
latie leatioeri am ceirrints *larking en an Aisait eit Tutu Mtinegime-i, ii
lein Angeles. awn epee may ottioduigI the OM f tlx) Wham Im1us1r I ati% rreqn:h
01114 einkeilif* the ciodaratida of olhor mlrettccual4 m the Wel I furl hem asked ea
Mg** die psmamJ aredeatede at Mr uteAn l niest It is es, prettattstiol optrliL u.
tiegief van iny pateenei atpiabillanet linaeriethleof We lir,Inete taterm. thin
WWII **Man director of ractreordanatry abate who ranks einem the prata41 pierettlem at
keetin ottitaioionW3 at Ten top of be field.
VIII* admire Joan 'tat elnend and 'and vo a rioasumr * war:. terai tkrio a tairtaad
pittann. Judatrig b, the high great Inliterlin of the taelperates with s.h.411 he rtaguial:
soda. demety I ow not the gully WO into apporiatica his tallow Hia irxhusi sow ell
in ow at the iletiego Most putiatif pubficationa reaching litotarly asillians 3i adiatteis tie
Ii pI*IICII*ttj binentO for Ms rat ot advvrrnall-4 and rd,iixleti went Nor
cantilinittrin hope diem, siitis asWein Intin, 0004 Christian Dii+ haw orcund
hint yoliticei as one of the issiting, 11*-Alt Wanton an dervictora *aria* vid3y. Jean Ler
Brunet is the consuatunate geldnagoata Iwo it tomes to the an at Illabion and hie walk a
aeon ttlec4ayeal U. emits towns Mei esearierics A true wise, be as alistoritteal Co the
lealliaattaors of est ebnIni an ow," *ovation. ditheatih Mr Oramai cummunt.is the bobtail
10X110$31163M for ligia Midi. be a fl vetegb the tweet
Ur Jan LW MUM IngturAwmitity an .nitIvIduAl of eatroardsnan nem,,
iatoratatiorsd anittawvenent and ogitmewiledispient. !ma how soy giaesiitegeas tripluktule
tk bun& e entireeetinen abtarv, oteaa* feel bet to tortUttt me
Thsakgew fat row ititinailye Min consmittanon.
GREORADELSTUDIOS
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10.411110010Manignot•No
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MIS
Voramit8WIdee Omar
110.01,40%biletteit
IL Alba" Vt 0$09400
BI: Diliasimeatreestvhis helm am Wallet Joe Um Muni
Doak te Madam
?MA WW1' whey to se--ppurt the is applitmloo of Jezo tAx Ortabd so that he maiy ba =lorded 0-1
eittradimity obi* *kw otovs to o:Intinue taexpaiad vim los alritady mammals& moot fie tbe
wcetdidde ttahtes indostrj. I ari tbo Ptothavtion Manager at Gm ;Wel Sirtodlos, its1 wand
ifititiltaCkaitato ILS VOvitle Raga, MIMArti, hthoureto. Vogue Chronvoi, irStigrei atzl Alum
Jaen i410 *mei Iwo booms tocivos mil, mil dem in Our fielf at 601011011 .4110 %IS Irtfalilht,
=rasa arml dfrect kaki= models fir clients, phottgriphoms, sit M. host Luc Smog hot o tilde ed
el* to aelixt the moat appropriex models to be urriccl. T1-aA athsatikeing eamytalsp, maul aditerruemfly haa
the nutria:adios akility to manage all stages of the compirrz ;:ittoreas of product:1i the Tit moda frIr 2
job. Thergfora, guar): otr bkv vs irt
mik erottible as tic la We o btsetill I mash, Ma
mat he hhot betemoing one of the profestictruils of choice for the fashion m4iy aact atketcream.*
athaetri re.
rn iny opie Joke Leer Band. is emotya hotilvithol el itStriardloary uhili‘ in the fled of art, sod
tbs pamitiela be will anaume in the Ward States dearly =gums am ilaclividuaI oi extrzaariEllgrf ilbraity tn
tiilLSea Mt rumel tin Imo inoozotimodly ham Mid iseognized foc; his tudque tab* lad
esperdoe. the malelp lis findo neduir wane bk the mot prookkee, hzhion publicati,os amubd
*ti worI4 melt to Sao Mworisot, Clasompoltion, Mario, Needuttas bit 114-14era eretribetioon to
ata)or dieult iiorye secured km a positioo ow of So leadiog dreftotshdUnit econSzeocrsi
weeithig today, ft is aho minim that the reapontataities anti digitsM&n inteMiltintill art &Tartar,
-orb° colithumes with the met dietiAgakchett magnum* and siimadoi &obi, rewire an sndivid.tal
af estraordiaali Ability and tOffiRvethntiovis aorit /0 Mr. Jeep LUC BMA
Iltrooted 0-veboi to *ark it the United eltaiea. Jam Lag Bound grill moo* bring him pbee
Was tborAzoodoui nutria_
Mous do not Wade to =we swy poosttors
montage
um= Lk :Kul,: rimb* ti.. 1. 4, Niale
%mot Bewley Centel
75 Lower Walden Street
Sr. 4)baaa VT ofieakcpoot
0-1 biondtranignmt Vise Petition co hdialf ethers We Emil
Mot Mr Of Madam:
Sly roam is, Nadia Ceram end I am Ploadeint of Montage Mrxicis.1 I haw
3o years of cAperienc* and I am con itantty to coma vvith professionals all
CIVier the mrld. A few ok my Clients irwlufir Elie Magazine, :A MOWN
Ramos, Laura Shop. Oglivii`s.71w ila; Store' —and sti on. A6 Audi, I
am tpialified to ammo on Mr. Jean Lc Brunei's weer as 1St
director of tnrtraaedioset, ebditl
Itissenemly because of his act lunation' or his hopeomioe WO; af work
that babies **earthing mid publishing szecutiess mound the: world
damns to abbe Mr. Brinier, greet Wan for their lesluvrileti accanrits. Mr.
Jeen Log Brunel is also an absolute apart et Webbing his chaps with
e: wily the image of their deals*. My ptirtonutl appreciation of Ur. Brunel
mem fe meg foe or to compn-hend his acclamations. Proien my
they MITT certainly well conibund Meardiewiy, Mr Brunel le In
to connared liaatsie compennetion for hie WO rk es compares to
in the buslacee
Itr. *ir! reputatIon ala fonnidable ;nibs: with a perstxtabla deaior
precedes him. He in constantly researriting end developing stintu tingly
rw alaSipti for his disco sad I h4we come to My on and trustMm and
his ability. Ow the coarse of his celebrated meet. Jean Luc Brunel lhaa
ablinguidted himself as tor of the Wats tednon art dixeetorsi in the
inanery.
Mt. hut Lot Snail er,Juys soexbaordioar, relationship to the
This quality resoliesb itseN *mash the bamatifid work ar ereittets, time
afttx Woe. Therefore, Joao bat Sruad is dimly otse of thr most talented
peafestiaanis working in the world today. I look forward to meek* vorr of
ILiaw the future.
glinenteb• own,
Media Como'
11111111111111,
NORDS1'1?()M
Ssatember 17. 2014
MSC*
Vermont Salvias Cedar
78 Loavatildilden Mist
Una"VT03479-0001
SE; 061 Itonminagrant Val Annan an Whit of loan UM &Una
OM Sir it Madam
tumid gm IQ *Mid mri NA and tirigusalled supped for the adrasidinaly *bay Gil visa
Podflort itidneid 11,V Ms, Joan Lua Wand Am the UM? NOM Piadister &iv
$ocdWom I am uwidnord to say the Mt AMP Luc finaid is an art *edits( and talent
scsadinailar at P4 highsv Whose Isclintain excalionce and creation vista have
Wald hall tit the lap ri his peolassion.
Thropohnia Mr .liam L une* dei5nguisihed resi, he n riicolvoti a high17
hiptiklahlel id al ainfessiono‘ WW1 nr4 ediwriremeni* i Pie Peg tOw YeiniPh
Braid Us *tot, Ind beautiful modals that haw appeared Ins list accfittir,en projects in
Mina at Ile oast tenkvaid publications in the wtd, which swats as a tommunt to ids
I arta aoratieni ninon ba the amine and aperalianal skits of iftley C171ankiV dnecbori
people, imbibe an diactirs and talent catatilnassta. It is Shirsdora tiv piestais se
micalantwe tha nensaliabis %dant and adVavarrisots of Mr. Joan Luc HT WWI 1, Kt 1111•40011
fiGhierkae the slitanaest wails Mate the teed cared*, dwireioped creative -concepts aril
MN* 111 is his *rely unique abilityto eennuriCele„ me lareiii analysis, the intended
=eft onSids90 of he onsets. Si. obier that M. Jim Luc ening* teicastoo fly onYclId
the swags Mods trx this Industry by it* slum** MOM VIM wt& Ns work
consiciered Initssd, no hill IVOrkta 110010 Of me bootiutorm wows Won
11011.01L Sad insgatinse In es wand it is wIllitaA a doubt thst I blisos an Op the -Ro& ce
fat way bat in his prolasstin
I an tallfidaltily Mit* that Mr. Assn Luc Owner's %lavish:in nu unwed inisinalkend
*dirs. iirt his reactod s level where industry Indere now describe hilit as a "star.
glawi tun aruners areVaordiruity arm it it a pooisA oPierteilleiret Nina timing tea-
Liza MaelOW
Senior Toiled Pradister
nornornns
%it silkl fluo
Recommendation Leiter
22/09114
USCIS
Vermont Service Center
73 Lower VieMen Street
St. ,Albtoss. VT 05479-0001
RH. 0-1 Non-immigrant Visa Petition on behalf of Jean 1.1w Brunel
Dear Sir or Madam:
It is an extreme pleasure to write a letter of recommendation for Mr. Jean
Luc Brim'. I 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 leurtashkir, director of I Mother Agency.
Kiev. Ukraine
I have known Jean Luc Brunel profelmonally for several, years through
cur work together and, an my opinion, he is an extr,inely talented
Individual with superb proiesstonal reputation. Hi s an :extraordinarily
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 ability to
recognise the creative vision of his client within the ton and budget
through his careful and thoughtful choice of model caning combined
with his meticulous ability in the field. Jean Luc Brunel si true find in
our industry.
There are plenty of ar directors out there, but none with the depth and
quality that Mr. Brunei possesses He is unlike anyone in this industry,
and I expect to see him continue to find great modes in his auccessilli
career. Someone overflowing with talent as Jean lAre Brunel should be
given every opportunity to work in the. United States where he will have
the proper venues t.,1 showcase his extraordinary talents.
Please do not hesitate to contact me should yists have any questions
regarding this matter. Thank you tor rout tinge and c6nsideration.
Sincerely,
Vladimir Yudat h
FiGaro
PIIII 1111116C09P 11,11141111 11101047
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30 Houghton &mot
$ad Mews. VT 0847$
Number 1517141S
M1?, Nt4
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MODELWERK
T401 ;AN I tiambil
.6o4 I I .';,,41c 11460f%,
El "Um ta !I • III 11!'
Alaxklvorli,
Hamburg 8 July. 2014
Deporfrnenl of Homeland Securiiv
United Slates Citizenship and kr -nigrah:on Services
Vermont Service Center
30 H.D3.,ightorl Street
S4011 Albans. VI 05478
Re: 0-1 Extraordinary Atitily as an Ar Dire cc and 'latent Cocrdinatcr :n
behalf of Jr-Luc Didier -.enri-Reno bum!
To Whom 'I May Conce—i
As a P•35ideril of Morietwcrk. his letter is suorriited in suoper of tAC2
Models Miami. ,.1.0 or behalf of Mr. Jear. is Brunel -0 work as or Art
Director and Talent Coordinatc,,
Mr Brunel -.olds an 41e-iatIonal repufallor as a visible e'alegic
netwomer who 'I able "o cultivate expert relationship management *Ns
order to conduce business in a global er.vronmen° and brocr-, ocrarive
deals. Mr. Brunel Ms a long listory mariKe-rig and ClagefilV lg rreitOf
fashion campaigns. Throughc..at rim twertiN-five year COreeri me folg-:cn
business. Mr. Brune has developea wor<twicia Oxc.usve triodclirci 3,vti
cosmetic campaigns. Some of Iheie -notor cosmeric carnpc.\;ns include.
Blo Them l with supermodet uie rvic'.Thersor.. PHA w w.eklecca hrorm-$.
Christian Dior with Ctulshns,i seinCtiViCiVi<ay0 Margret Asiqr with Monica
Meucci. Chariot with Plaiiir i Vf RicAervie.irr, ofkrge PsriJone rth Thery
Mugler. and Cacho(' ",erturne wiN ' t. fiallestra. Mr..3!7+Jrpe has alsr.,
developed major fashion z.:;_;rr,-,):4ris ono Irios icsevt rped campaigrs ord
exclusrve cavracts -no of the fast- ior 477, Such rii
Yvel 50011 toff:y-0. Chondi Clristion Dor.
4000M.
;In addition to Mr. Jean Lur Brunel s extor.iive bijsinev;
comer as Ws indimtua witn artistic vfl ono creoNe to
him Nnd top fashion models tn reoresent Ir the United St at
Should you have Ony Questions °boil Jeor _uc Nnei
feet tree to contact me.
PreSictene4° au " ;e' 1')
tviodekverk \filiiiviarctilitr I;mill I
Marc
otaltationq. Its
nh ha s helped
I wr...110.,;:-.V-ce-is
meeti,v vesv-auv
Aly 11.70'4
01001meni el Nontstext Sec"
United Motes Myer WO and intrnigrolion Solviass
Vermont Service Cartier
30 Havgision Sires'
Saint Alban rer 05011
Re: 0-1 Etertxvcinary 103110 as cn Ad Meek/ Toient Coordinator on
behalf at Jean-Luc Cr tlerwiliene Brunei
TO Silvan tt may Concern:
As a President al fiataBe PAWNS Management tvi tenet is fitornoted in
waiscst es mC2 models mzrr.. LIC or Denott ot mi. Jim Luc asurffaP ft
wok as an Art Director arid Tamen, Coadnalar.
sat Brunei hold; co ritemotienol repitallon CtS oVISIbk. CkCitegiC
nelerotter who is obse to cullivase evert fosalionsila management skill
cedar 10 conteXt Dullness Via giatal ereinxweerd avi tvolier luoratree
deals. hir inter has 0 long testacy in maiming and atIvertiong /Tao
ladian campaigns Tryoughok.i his twerriplive yew career In lee fashion
bushes& us. Brunei has developed vitifft•vidt ISCS:StvisrdI crld
cosmetic comp:Ion" Sone of these maior casnedIc ccimpolcrs include;
o Therm wen eiparritodel Be mcPowno4 f41104,S with RebeCco kw*.
Chilean OW talith Christina Semonnorskom Margret Asia viiith Monica
Meucci, Monet Win Potticio Von Rickonheim. Angel Pedume with Triseny
hissfer. and Cot:hotel Parikene VAN' Aldo Sokoto. S. &run& has do,
demaidPad rnalor fashicel campaigns cind has clvelOped campaigns end
attar** contacts wilh some of the rvoltCrS 10p koshiCal clessgnors SuCh cIS
Yves ScIrd sward. Chanei. Christian Dict Gucci Prado. ond Marc
.i0c0Os.
ji&.4-ji-ntaro MAIM Ur lorittlAta.13 ailla a /a, 407.3 V.1011 'Areek44
lair 3 an Psi arm. .11. psi Jssm, puts netagrelopplal,_ "WY., nalss aarn-cdath.
Qin 1,414X0iLIS241, & PARLIKSS IONA Lads PARSAW forts a 16 nal gixo ci• A
en WOW to tic Joan Lac guide's eiders*. bLisifiele
MOW Cs an incilvkilai with *MSc Alm eV ONIelvetoiu,i4 1161 MOW
Plint MO top tookiart elcAseis so nsprissont et Ms tinted Slates-
Mead 'Mu hove any gumboils about Mr. Man toe Slung
feet iree lo cardact mu,
ii
Vermont Service Center
Attn: Premium Processing Unit
30 Houghton Street
St. Albans, Vermont 06478-2399
Facsimile Transmission
To:
LUIS FONT
Cirtzenshi
and
Services
Fax Number: 19542414272
Number of pages including cover: Date: September 6, 2014
From:
Email:
Receipt Number:
Vermont Service Center — Premiirn Processing Unit Fax Number: W2-288-1778
W.; PREMIUM PROCESSINGODHS GOV
Phone: 1-865-315-5718
Attached you will find a copy of cu decision concerning your case
The original decrsion will follow via mail If eligible to appeal our decision appeal forms mil be included
—Important—Important-4'lmportant—Important-**
If responding to a Request fa Evidence or !lent to Derry. ensure you include a copy of the decision immediately
following your cover page and indicate the total number of pages included with your response Please include the case
receipt number (e g EAC01 000 12345) with all correspondence
Ensure when responding to this request that you fax your response to our NEW FAX NUMBER - B02-238-1778
if you wish to mail a response, it must be sent to the VSC Premiirn Processing Unit at 30 Houghton Street, St Albans,
VT 05478-2399 Do not send your response to the 75 Lower Weiden Street address, as that will cause delays and will
not restart the premium processing clock until the response is identified as a premium processing case
Title 8 CFR Section 103 2(b)(11) Submission of evidence in response to a Service request states
All evidence subenMed in response to a Service request must be alornitted at one time The submission of only some
or the requested evidence will be considered a request for a decrsicn based on the record
This communcabon a ritended far the sole use of the individual to whom it is addressed and may contain inforrnabon that a prmleged confidential
and exempt Iran disclosure under applicable law If the reac, of thrs corrimunration is riot the rlended recipen1 or the employee or agent for
delvering the communication to the intended recluienl you are hereby netted that any drssernrialion distrkiuton or copyrig of the communication
may be strrtry prohbled if you received this comrnunrcation ri error please notty the sender arTracirately by telephone arid return the
communicator alume address above use Lin led Slales Postal Servre Thank you
www.uscis.gov
U S Department of Homeland Security
U S Citizenship and Immigration Serviirs
Nonce ot Action
Page I of 4
Applicant/PetItioner A #
Appncation /Pent ;on
Petition For A Nontninitp,rarit Worker Minn 'a
Notice Date
August /6 1014
Response due by
November 21, 2014
MC2 MODELS MIAMI LL(
LUIS FONT
FONT LAW GROUP PA
.1440 HOLLYWOOD Ita 511 41j
HOLLYWOOD IL ,1,1021
1-4 At. I 4Z. Z55(iN().-1
-EAC14/255u803
Applicant/Pelitiotier
MC2 MODELS MIAMI LLC
beneficiary
BRUNEL JEAN LUC
Receipt Number
EACI4//550803(II 19)
WVIUM PROCESSING
IMPORTANT THIS NOTICE CONTAINS YOUR UNIQUE NUMBER AND MUST BE SUBMITTED IN TliE
ORIGINAL WITH ITtE REQUESTED EVIDENCE
1 U S Citizenship and Immigration Senaces iUSC1S) requires additional evidence to process your form Incase provide the
evidence listed on the attached pagets) For Form 1-129 only, if you are requesting consulateembassy notdication, provide the
requested evidence in duplicate
2 Your respe must be received in this office on or before NoNeinbef 11 1014 Please note the required deadline for
providing a response to this Request for Evidence The deadline reflects the mzumum period for responding to this RFE
HilWetiet, since many immigration benefits are time sensitive, you are encouraged to respond to this request as early as possible
but no later than the date provided on the request You will not be granted an extension of time to submit the requested
evidence
3 You must submit all requested evidence at the same time If you submit only some of the requested evidence, L'SCIS will
consider it a request for a decision on the record [8 ('FR 103 2ib1t II ii
4 You will be notified separately about any other applications or petitions you have filed
5 From the date this office receives your resubmission, a minimum of 14 days will be required to process your form If you
have not heard from LISCIS within 30 days, you may contact this office at r866) 3[5-5118
6 Mad this nonce and your response to
VSC heiruuni Pressing
Vermont Semce Center
30 Houghton Street
Si Alb-ans VT 05478-2390
vs- premium piote”iniatihs Qv
U S Department of Hornefrind Security
U S Citi2enship tind IMrnigrdtion Servites
Nonce of Action
Pagc 2 of 4
EAC14ZZ550803  (!jig! ___________________
Responses flor Preini um Processing cases only) may beloxed to (8Q2) 488-1778 Include a  copy al this
notice Thee inail address may only be used for inquiries Do not send responses to thee mail address
I. I d9 0- Ili Extraordinary Ability in the Arts
1 ou MCZ Models Miami LLC hied Form I 1Z9 Fetilion lor Nonintringrant Worker seeking 0 lit MII)Ift11111gRI11
classification liar Jean Luc Brunel as an Art Director / 'latent Coordinator
The 0 .113 classification applies to individuals with extraordinary ability in the arts The individual must have sustained
national or international acclaim His or her achievements must be in the tiekl of expertise and show a record 01
prominence in his or her lipid
1G process your pennon and determine ml the beneficiary is eligible additional information is required 1 his request
provides suggested evidence that you may submit to satisfy each requested nern You may
Submit one some or all ol these alenis
Submit none at the suggested items and instead submit other evidence to sa1is4 the request
Explain how the evidence in the record already establishes eligibility
Request a decision based on the Ter071
Note poweveLthal, yQUIff ff5PPMfble lqr PrOviding evidence thatlksi  shows thaLyo  and the pIrtie ipstin_pplitigh
meet all requirements Evidence must show that all parties were eligible for the requested benefit when you filed Form
I 149
General Requirements Inr All 0 Nomintrugrant Petitions
In general petitions seeking 0 nonimmigrant classification must include
Copies of ontracts
A description ol the competitionts) event (st or pertormance(s) and
At least one consultation
To saint, these requirements you submitted
- Your letter in support ol the petition and
Peer letters in support al the beneficiary trom Claudia Muloto and Alla Amaniova
Beneficiary s Previous 0 - 1 Status
Petitions involving an extension al status lor a beneticiary that has previously been gt al.te (I 0 1 nommringrant status
may he given deference however U S Citizenship and Immigration Services (USC1S) is authorized to question
extension petitions when a substantial change in circumstances occurs when relevant lads change lrom one petition to
another or when the prior approval may have been based on gross USCIS error
)ou militate that the benenciary was previously granted 0.1 nonimmigrant status with your company The details of
the beneliciary s previous employment with your company are not documented in the instant petition A review of the
evidence submitted indicates that it the beneficiary's role within your organization has remained unchanged the
previous petition may have been approved in error. as the list ol duties you provided do not appear to descnbe a
FOR oFFKI USE ONLY
Form I 797 (8/03/90) Y
U $ DeparlInciit of HOrrtland Security
U S Citizenship and Immigration Servic es
Notice of Acnoti
Page 3 of 4
MC14/4550803(1 I Z91
position in the arts
In addition DO evidence has been submitted to support your claim that the beneficiary is an individual who has
extraonlinary ability In the ails that has been demonstrated by sustained national or international acclaim Yu have
documented the beneficiary s past success in the business of tot ming and operation modeling agencies but this evidence
points to the benetiriarys ability on the field of business not the arts Therelore you are asked to comply with the
following
Contracts
Pennons seeking 0 nonimmigrant classiftratton must include a copy ol a contract between the beneficiary and either the
petitioner or the Pmpioyer II a wniten contract does not exist you may submit a detailed summary of the terms 01 the
oral agreement between the beneficiary and either the petitioner or the employer
You did not submit any evuleme lot this requitement You may still submit evidence to satisfy it
Wniten COniraciS or the summary of the Innis of an oral agreement must specilv the terms and conditions ol the
employment or services They must
Specify the wage altered antl explain the terms and conditions under which the benetictary will pertorm these
services, and
- Detail any additional services provided
Nature of the Event or Engagement
'Jou must provide an explanation of the competition event or pertomiance in which the N./IMP-My will participate
An event means an activity surh as a scientific project conlerenre convention lecture senes academic year or
engagement during the requested validity period
The description you submitted is insufficient In your latter you list the duties at the proffered position as
10'SpOnS11)1e 101 overseemg the artistic aspects at the agency (select the images placed on the model,
business cards ,:nd in their porilohos)
Coordinate the pairing of models with photographers
Direct the marketing of models to chents
Travel around the world 10 tint-Over new Ulm( and 10 sign them with MC Z Models and
Establish relationships with agencies around the world and negotiate representation agreements
The duties you descnbe appear to relate exclusive!) to the maintenance ot business cpvrations of a modeling agency As
previously stated you have thxumented the beneficialy s past success in forming arid operating modelmg agencies
however this e kicience points to the beneficiary s ability in the held 01 business not the ails It is not evident therelore
that the 0 18 noturturagrant classification is appropriate In the inSlanl case
Regulations define the 'arts" as any held of creative activity or endeavor such as but not limited to line arts visual arts
culinary arts and perfomung arts Ahens engaged in the held of arts include not only the princtpal motors and
performers but other essential persons such as hut not limited 10 directors Set designers lighting designers sound
designers choreographers choreologists conductors orchestrators coaches arrangers musical supervisors costume
FOR LARK £ US/ ()NIA
Form I 797 (/O3/9O) /*
If 11 Deo twin of Homeland Sr-runty
U S Citizenship (ind immigration Servii es
Notice of Action
Page 4 of 4
MC14 a 550803(11/9) ___________________________________________________________________________________
designers makeup artists flight masters, stage technicians. and animal trainers
The duties you describe correspond to business anti management fUTIMOTIS DOI to a position In the arts Before
adiuthcation of your petition can proceed this discrepancy must be resolved
You may still submit evidence to sanity this requirement
The desknplion must include
An explanation of the nature of the events or activities.
Beginning and ending dates at the events or activities. and
A copy of any itinerary that shows dates name(s) ot the employer (s) and location of the event (s)
You mot establish that the proffered position qualifies as a position in the arts as described above Any and all claims
must be Why supported by documentary evidence
FUR ,FFP.. I USE uNLI
Form 1797 (8/03/90) Y
FONT LAW GROUP, P.A.
3440 Hollywood Boulevard, Suite 415
Hollywood, FL 33021
Tel.: (954) 241-4271 Fax: (954) 241-4272
November 3. 2014
Director
United States Citizenship& Immigration Services
Vermont Service Center
75 Lower Welden Street
Saint Albans. VT 05479
RE. NOTIFICATION OF WITHDRAWAL OF 1-129 PETITION
WITHOUT PREJUDICE BY PETITIONER
EAC-14-225-50803
Petitioner: MC2 MODELS MIAMI LI.0
Beneficiary: JEAN LUC DINER HENRI RENE BRUNEL
Dear Sir/Madam:
Please be advised that this office represents the above referenced petitioner and beneficiary in
this immigration matter and a G-28 from our office is on file.
THE PETITIONER, MC2 MODELS MIAMI LLC HEREBY NOTIFIES USC1S THAT IT
WISHES TO WITHDRAW 1-129 0-1 PETITION #EAC-14-225-50803. The petitioner requests
withdrawal of this 1-129 petition without prejudice. Please note this request for the record in the
above referenced case.
We respectfully request that you send us verification of this withdrawal pursuant to the
regulations contained in 8 C.F.R. Sec. 103.2 (h) (15).
Kindly send our office a written verification of this withdrawal located at:
Font Law Group. P.A.
3440 Hollywood Boulevard. Suite 415
Hollywood. FL 33021
Thank you tbr your attention to this matter.
---- 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 Conchita Sarnoff 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
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 choice.
Thanks,
Jeff
Jeff Fuller
President
MC2 Model Management USA
EXHIBIT K
FROM: JACQUIE JOHNSON <.J.JOIINSONaiRRA-LAW.( 'OM>
DATE: SEPTEMBER 18, 2009 3:57:44 PM EDT
TO: "'TAMAQTKUDNIANLAW.COM" <TAM.VerTKUDMANLAW.COM>
CC: "BRADLEY J. EDWARDS" <BEDWARDS4RRA-LAW.CONI>
SUBJECT: EPSTEIN - DEPO OF JEAN WC BRITHNEL
We have confirmation for Mr. Bruhners deposition on 11/3. We will commence at 10:00 a.m. if 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 Lauderdale, FL 33301
Telephone 954 315 7264
Fax 954 527 8663
JiohnsonOrra-law.com
EXHIBIT L
---Original Message—
From: Tama Beth Kudman <tama@tkudmanlaw.corn>
Date: Monday, November 16, 2009 at 7:48 PM
To: Jean Luc Brunel <2jeanluc@gmail.com>
Subject: Re: Hi
>All depos are cancelled for now. A letter confirming this is being
>Sent out today. We have no idea how long this shall delay things. I'll
>let Michael know.
>
>Sent from my iPhone
>Tama Beth Kudman
EXHIBIT M
From: "Dr. Royce Jalazo" <dynamicbeh@gmail.com>
To: joetitone708@comcast.net
Sent: Tuesday, December 23, 2014 2:40:59 PM
Subject: Jean Luc Brunel
Mr. Titone,
Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an
outpatient individual psychotherapy session with me on 12/12/14.
Thank you,
Royce N. Jalazo, Psy.D.
Licensed Psychologist
Dynamic Behavioral Consulting
a DBA of Dr. Royce Jalazo, P.A.
1975 E. Sunrise Blvd., Suite 532
Ft. Lauderdale, FL 33304
Direct (With Voicemail): 954-232-7092
Toll Free Fax: 888-236-6979 or 954-208-3400
E-mail: DvnamicBeh@qmail.com
Website: www.DynamicBeh.com
EXHIBIT N
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MR. JEAN - LUC BRUNEL
Prozac (20 Mg) Capsule #
Take 1 Capsule
Once Daily After Breakfast
0141221248
02/12/2014 135,53
Tel. 02.680-2700 Fax. 02432-0S17-9 wend ON
tnwEran
BNH H
.c, „„ (Bangkok Nursing
MR. JEAN LU
Rivotril (2
Take 1 Tablet
Once Daily Before
(It May Cause Dr
EXHIBIT Q
EscortAgeosy.
ft/Or =doling money owriat ion. Luc &t4nai who covana Oat LIC2 meactcy in Miami Sawn, &wort
Mho Woe to Ingot and firml lhamaehitia ontinarad ta a
itvAnclarwalbola:644/as.yi ottgoituido-llorda abo-ikialapaltorgtoliancioloricia-1, filic011-
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http://www.politico.com/blogsiunder-the-radar/2014/12/court-filing-levels-sex-claims-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
Brunel'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 18-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
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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 me 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.
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While "Jane Doe #3" is unidentified in this week's court filing, her story appears to track with
that of a woman who sued Epstein in 2009 and settled with him later that year. She apparently
granted an on-the-record interview to Britain's DailN Mail in 2011.
Some of the fascination with Epstein on the part of tabloids and glossy magazines stems from his
ties to former President Bill Clinton. In 2002, Epstein provided his 727 to Clinton for a trip to
Africa to study anti-AIDS programs. Celebrities such as Chris Tucker and Kevin Spacey came
along for the ride. The new court filing makes no mention of Clinton, Tucker or Spacey.
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. However, U.S. District Court Judge Keith Marra ruled last year
that the victims are entitled to examine those records to prepare their case against the
government.
Epstein, Black and others appealed that decision to the Atlanta-based 11th 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.
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-------- 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 Bechtal [m ai Ito : erik@pageparkes.corn1
Sent: Thursday, January 15, 2015 5:12 PM
To: Abi Schwinck
Subject: Victoria
Hey Abi1
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
v‘, w.patleparkesage ncy.com
The Page Parkes Building
1535 West Loop South, Suite 110
EXHIBIT S
Houston, TX 77027
P: 713 807.8222
F: 713 807 0055
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