Epstein Secrets

Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YLORG Case No.: 14-21348 CA 01 Dear Judge Smith: Please find enclosed a courtesy copy of Defendant, Jeffrey Epstein's, Response to Motion for Ruling on Service of Process on Defendant, Jeffrey Epstein without a Hearing. Because the Plaintiffs attorney, Mr. Titone,

ion for Ruling on Service of Process Defendant, Jeffrey Epstein, filed his Memorandum in Opposition to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plaintiffs failure to properly serve him in what is now 2 years and 10 months after the filing of Plain

that failed attempt. 3. The undersigned counsel promptly fded a motion to quash on behalf of Mr. Epstein in April 2015, which motion included Mr. Bpstoin's affidavit confirming the location of his residence and usual place of abode in the United States Virgin Islands. 4. Plaintiffs waited a full yea

dividually and MCI Model & Talent Miami, LLC vs. Jeffrey Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YL

tion to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plai

E WCB/msk Enclosure cc: Mr. Joseph Titone, Esq. EFTA00788364 • Filing # 62990957 E-Filed 10/18/2017 12:26:18 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, vs. JE

IT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. MEMORANDUM IN OPPOSITION TO MOTION FOR RULING ON SERVICE OF PROCESS Having already on

4, Defendant Jeffrey Epstein was not even a party. Plaintiffs amended their complaint in January 2015 to assert two non-business counts against Mr. Epstein personally and caused a summons to be issued on February 9, 2015. In more than two years since Plaintiffs amended their complaint to include Mr. Eps

C2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/

y 2015 to assert two non-business counts against Mr. Epstein personally and caused a summons to be issued on F

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JE

ally, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMES NOW, the Defendant, Jeffrey Epstein, a resident of the United States Virgin Islands, by and through his undersigned counsel

2015, Plaintiffs improperly attempted to serve Defendant Jeffrey Epstein in New York by leaving process with a woman at a location that was not Mr. Epstein's usual place of abode. Plaintiffs never even filed a Notice of Service of Process in connection with that failed attempt. 2. The undersigned cou

C2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/

g process with a woman at a location that was not Mr. Epstein's usual place of abode. Plaintiffs never even fi

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JE

& 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

DRAFT IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CIRCUIT CIVIL SECTION 34 CASE NO. 2014-21348-CA-01 JEAN-LUC BRUNEL, individually; and MC2 MODEL & TALENT MIAMI