Epstein Secrets

9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/2007 Subpoena to Eric Gany (return date 9/11/07) 8/17/2007 M

urn date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr

(return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr

's lawyer 7/3/2008 Villafana Brad Edwards and Jay Howell Letter advising of representation of Epstein vict

9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/2007 Subpoena to Eric Gany (return date 9/11/07) 8/17/2007 M

urn date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr

(return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr

s lawyer 7/3/2008 Villafatia Brad Edwards and Jay Howell Letter advising of representation of Epstein vict

MARRA/JO HNS ON 08080119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NON-PARTY, JEAN LUC BRUHNEL'S RESPONSE TO PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUS E AND FOR AN ORDER TO COMPEL AND 'NCO RPO RATED MEMORANDUM OF LAW Non-party Jean

e and for an Order to Compel and Incorporated Memorandum of Law which was filed on March 10, 2010. (DE#483). Plaintiff's counsel seeks to compel Mr. Bruhnel, a french citizen who is not a party to the instant action, to sit for a deposition that was canceled and for which he has never been re-noticed. T

9 to: Michael Burman, Esq., & Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq., Jay Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan Goldberger, Esq., Atterbury Goldberger et al., 2

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible eviden

ead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the disco

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible eviden

ead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the disco

tion by Edwards. Upon teview of the message pads that were taken from Epstein’s home in the police trash pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pals. He left messages for Epstein. One dated 4/1/05 said, “He has a teacher for you to teach you how

“EE.” In light of these circumstances of the case, this message reasonably suggested to 24 HOUSE_OVERSIGHT_013342 --- PAGE BREAK --- Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press reports reviewed by Edwards, B

pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pa

See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidenelne Jean Luc Brunel. (JLB) staying at his house during that relevant period of time attached Exhibit “JJ”. As a result, Edwards filed a Motion for Contempt, attached hereto as

vil litigation against Jeffrey Epstein for sexually abusing them while they were minor girls. I agreed to. represent these girls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of L