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, 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, and files this Motion to Dismiss, and. as good grounds therefore states as follows: 1. On October 5, 2016
pstein's, Response to Motion for Ruling on Service of Process on Defendant, Jeffrey Epstein without a Hearing. Because the Plaintiffs attorney, Mr. Titone, is asking by way of his motion that you rule on his motion without a hearing, we are concerned that Mr. Titone may provide his motion to you direct
l 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
om: "Dr. Royce Jalazo" <[email protected]> To: [email protected] 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/
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
: "Dr. Royce Jalazo" <[email protected]> To: [email protected] Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this e it al notification that Mr. Jean Luc Brunel attending an outpatient individual session with me on 12/12/14. Thank you, R
n its order granting Brunel leave to serve Epstein (Defendant's App. E, p.48). Additionally, Brunel did not serve Epstein at his home address in the Virgin Islands, as Epstein lives on his own private island (Little St. James), which is inaccessible to the public (Defendant's App. F, p.62-65). After Epstein's
APPELLEES/PLAINTIFFS On Appeal from a Non-Final Order of the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Joe Titone Attorney for Appellant Florida Bar No. 203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: (954)729-6490 [email protected] 1 EFTA0
, 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, and files this Motion to Dismiss, and as good grounds therefore states as follows: I. In complete disrega
CERTIFIED that a true and correct copy of the foregoing has been electronically furnished via email and/or E-file on the 29th day of March, 2017 to Joe Titone, [email protected]. W. CHESTER BREWER, JR., P.A. Counsel for Epstein 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401 (561
Entities connected to both U.S. Virgin Islands and Joe Titone

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Richard Kahn
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bill Clinton
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Virginia Giuffre
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Lawrence Krauss
PERSON
Joe Biden
PERSON
Jean-Luc Brunel
PERSON
Lesley Groff
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON