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i.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
onald”) 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
re high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night caro
gated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel and/or by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that B
ald") 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, b
e high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night caro
ated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel and/or by his fellow agent, Claude Haddad. Even at that time. Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that
re high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night car
ted Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel and/or by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that
Entities connected to both Donald Trump and Claude Haddad

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