Epstein Secrets

FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the

of that case for your ready reference. It is now almost two years past the January 2015 filing date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in August 2014. I remind you that no attempt was made to even serve Mr. Epstein until March 10, 2015. I

of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear

date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in A

December 7, 2016 Via Email: Joe Titone, Esq. 621 S.E. 5th Street Pompano Beach , FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in th

IN THE DISTRICT COURT OF APPEAL OF FLORIDA THIRD DISTRICT DCA CASE NO.: 3D18-1997 L.T. CASE NO.: 2014-021348 CA 01 JEFFREY EPSTEIN, Appellant/Defendant, vs. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, Appellees/Plaintiffs. REPLY BRIEF OF APPELLANT On

es and Other Authorities iii EFTA00808438 PREFACE Appellant, JEFFREY EPSTEIN, was the Defendant below and will be referred to in this brief as "Epstein." Appellees, JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, were the Plaintiffs below and will be referred to in this brief as

NO.: 3D18-1997 L.T. CASE NO.: 2014-021348 CA 01 JEFFREY EPSTEIN, Appellant/Defendant, vs. JEAN-LUC BRU

EBY CERTIFY that a true and correct copy of this Reply Brief was served on this day of December, 2018 by electronic mail to: Joe Titone, Esq., 621 S.E. 5th Street, Pompano Beach, FL 33060 ([email protected]). LINK & ROCKENBACH, PA Counsel for Appellant 1555 Palm Beach Lakes Blvd., Suite 930 West Palm

& TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG

C2 MODEL & TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b

; and MC2 MODEL & TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG, Defendants. DEFENDANT, JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO PLAINTIFF, MC2 MODEL & TALENT MIAMI, LLC Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby serv

o. 2014-21348-CA-01 Jeffrey Epstein's Proposal for Settlement to Ma Model & Talent Miami, LLC Page 3 Joe Titone, Esq., Counsel for Plaintiffs, 621 S.E. 5th Street, Pompano Beach, FL 33061, E-Mail by E-Mail, this day of September, 2015. W. CHESTER BREWER, JR., P.A. Attorneys for Jeffrey Epstein Phone Fax

A 01 Section 34 Plaintiff, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. / PLAINTIFF'S RESPONSE TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO QUASH ATTEMPTED SERVICE COMES NOW, the Plaintiff JEAN-LUC BRUNEL, by and through undersigned counsel, and files this, his Response to De

ols, the billionaire money manager — and registered sex offender — is importing his playmates from Russia, my source says. A recent visitor tells me Epstein has a house full of young beauties at his East 71st Street mansion. "Half of them are from the former Soviet Union and the other half are a mix of

e Caribbean (which he jokingly dubbed Little St. Jeff's) and his Manhattan townhouse. "When the Russian girls arrive in the city, they already have Jeffrey's phone number," said my source. One procurer, Peter Listerman, claims in TV interviews that he introduced many oligarchs and A-listers to Russian

ndant be granted another 120 days in which to properly effectuate service. /s/ Joe Titone Joe Titone Attorney for Plaintiff FL BAR #: 203882 621 S.E. 5th Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) [email protected] CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a

UDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL Civil Action No.: 14-21348 CA 01 (34) Plaintiff, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. NOTICE OF HEARING - MOTION CALENDAR PLEASE TAKE NOTICE that the undersigned will call

o.: 14-21348 CA 01 (34) Plaintiff, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG

Action No.: 14-21348 CA 01 (34) Plaintiff, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/

Flagler Street, Room DCC 416, Miami, Florida 33130. PLEASE GOVERN YOURSELF ACCORDINGLY. 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) [email protected] 1 EFTA00620175 CERTIFICATE OF SERVICE I HEREBY CER

SETTLEMENT PURPOSES ONLY E-MAIL YIA ONLY Joetitone708(iftonscast.net Joe Titone, Esq. 621 S.E. 5th Street Pompano Beach, FL 33060 Re: Unmet / Epstein Dear Joe: It appears that we will have to reschedule the hearing on our Motion To Quash. When we checked with Judge Smith's JA on April 18, 2016,

hat the Judge would not hear us. When I informed Mr. Epstein of the situation, he asked that I inform you that

.5086 TELEPEONE FAX April 2016 CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY E-MAIL YIA ONLY Joetitone708(iftonscast.net Joe Titone, Esq. 621 S.E. 5th Street Pompano Beach, FL 33060 Re: Unmet / Epstein Dear Joe: It appears that we will have to reschedule the hearing on our Motion To Quash. When we ch