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R AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to a
in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would
th in addition to being the girlfriend of 8 Jeffrey Epstein? 9 A. No. 10 Q. Do you know somebody by the name of Jean 11 Luc Brunel? 12 A. Yes. 13 Q. How do you know him? 14 A. He was in the house like, I guess, a few 15 times. 16 Q.
8 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay. And is th
ho pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 up. 6 Q. Okay. It wouldn't be Story Cowles picking 7 him up? 8 A. No. 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last we
ow this? 7 A Yes. What's his name. 0 Jean Luc Brunel. Do you know who that is? 9 A Yes. 10 0 How
u know this? 7 A Yes. What's his name. 0 Jean Luc Brunel. Do you know who that is? 9 A Yes. 10 0 How
living room? 2 A No. 3 MR. EDWARDS: What are we at? 4 MR. CRITTON: 5 BY MR. EDWARDS: 6 0 Do you know this? 7 A Yes. What's his name. 0 Jean Luc Brunel. Do you know who that is? 9 A Yes. 10 0 How do you know him? 11 A He comes to the house. 12 0 He comes to the house. When you say The comes
AM right. So this is during the day he came over. Story came over and visited with A Visited? I think so. Q Okay. Do you know the purpose for Mr. Cowles, or Story as you referred to him, meeting with at the house during the year time period when Mr. Epstein was in jail? 78 1 stayed permanently?
Was it somebody from New York? A What, you mean when he was jail? O When he was in jail. A Story. O It was Story? A It was Story. O This is Story Cowles? Do you know the last name? A I don't know his last name. o And when you say she came with a person, you mean she came to the house with a pers
ND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to a
d in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would
d be 7 intimate with in addition to being the girlfriend of 8 Jeffrey Epstein? 9 A. No. 10 Q. Do you know somebody by the name of Jean 11 Luc Brunel? 12 A. Yes. 13 Q. How do you know him? 14 A. He was in the house like, I guess, a few 15 times. 16 Q. When? 17 A. When? 18 Q. Whe
e 19 of 20 Page 168 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay. And is there anywhere where yo
am the one who pick up people. So, I guess it was my 4 days off and Igor was working, so he went to pick him 5 up. 6 Q. Okay. It wouldn't be Story Cowles picking 7 him up? 8 A. No. 9 Q. So, to the best of your recollection Igor 10 picked up Jean Luc Brunel sometime last week from 11 the air
0 1 day Birthday (UTC) 1979-09-18 [64] 00:00:00 1 day (UTC) 1980-12-22 [65] 00:00:00 1 day (UTC) 1981-02-01 [66] 00:00:00 1 day (UTC) Jean luc Brunel's Birthday irthday Nina Keita's Birthday 1981-02-24 [67] 00:00:00 1 day Erok's Birthday (UTC) 1981-07-05 Ryan Giunta's [68] 00:00:00 1 day
1981-02-01 [66] 00:00:00 1 day (UTC) Jean luc Brunel's Birthday irthday Nina Keita's Birthday 198
C) 1981-02-01 [66] 00:00:00 1 day (UTC) Jean luc Brunel's Birthday irthday Nina Keita's Birthday 198
rthday 1981-02-24 [67] 00:00:00 1 day Erok's Birthday (UTC) 1981-07-05 Ryan Giunta's [68] 00:00:00 1 day Birthday (UTC) 1981-08-19 Story Cowles's [69] 00:00:00 I day Birthday (UTC) EFTA00510023 1983-05-09 [70] 00:00:00 1 day (UTC) 1983-10-24 [71] 00:00:00 1 day (UTC) 1983-11-28
in the modeling agency, 11 too, correct? 12 MR. PIKE: Form. 13 A. I refuse to answer. 14 Q. That's a friend of or former friend of Jean 15 Luc Brunel's? 16 A. I refuse to answer. 17 Q. How many times has Jean Luc Brunel shown up at 18 Jeffrey Epstein's house with underage minor females? 19 MR
ed to 17 agency owners having sex with underage minors? 18 MR. ROSS: Answer the question. 19 A. No, I'm not. 20 Q. Okay. Did you ever hear of Jean Luc Brunel's 21 reputation for having sex with underage girls? 22 MR. ROSS: Invoke. 23 A. I refuse to answer. 24 Q. Do you know how Jean Luc Brunel knows
Q. I mean, helping to recruit models, helping others to recruit models, anything like that? A. No. Q. Do you ever -- do you currently talk Co Er. Brunel? 7 A. I refuse to answer. 8 Q. When is the last time that you talked to 9 Jeffrey Epstein? IC A. I refuse to answer. 11 Q. Do you know a wo
IKE: Form. 0100 1 A. I refuse to answer. 2 Q. Do you know how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr.
with me or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the loan. 11 MIL E
he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go bac
that he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go bac
owles about 15 this case on numerous occasions; is that true? 16 MR. YAREMA: Object to the form. 17 A Fifth. 18 conversations with Story 19 Cowles and your observations of them, you believe 20 would implicate you in a crime and that's why 21 you're able to take the Fifth as to that 22 ques
Form. A. I refuse to answer. Q. Who is Jeffrey Epstein's girlfriend now, if EFTA00182461 14 Q. That's a friend of or former friend of Jean 15 Luc Brunel's? 16 A. I refuse to answer. 17 Q. How many times has Jean Luc Brunel shown up at 18 Jeffrey Epstein's house with underage minor females? 19 MR
ed to 17 agency owners having sex with underage minors? 18 MR. ROSS: Answer the question. 19 A. No, I'm not. 20 Q. Okay. Did you ever hear of Jean Luc Brunel's 21 reputation for having sex with underage girls? 22 MR. ROSS: Invoke. 23 A. I refuse to answer. 24 Q. Do you know how Jean Luc Brunel knows
elping to recruit models, helping 3 others to recruit models, anything like that? 4 A. No. 5 Q. Do you ever -- do you currently talk to 6 Mr. Brunel? 7 A. I refuse to answer. 8 Q. When is the last time that you talked to 9 Jeffrey Epstein? 10 A. I refuse to answer. 11 Q. Do you know a wo
IKE: Form. 0100 1 A. I refuse to answer. 2 Q. Do you know how it is that met 3 Jeffrey Epstein? 4 A. I refuse to answer. 5 Q. Do you know Story Cowles? 6 A. I refuse to answer. 7 Q. You know who Sergio Cordero is? 8 A. I refuse to answer. 9 Q. Well, that's somebody who also assists 10 Mr.
Term: 05/20/2009] Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 Fax: 442-6744 EFTA01660044 United States of America Amicus Jean Luc Bruhnel Material Witness Date 02/06/2008 1 02/06/2008 2 02/08/2008 3 05/22/2008 4 05/22/2008 5 05/27/2008 6 05/29/2008 7 06/06/2008 8 06/1
0044 United States of America Amicus Jean Luc Bruhnel Material Witness Date 02/06/2008 1 02/06/200
rder to Show Cause and Compel Deposition of Jean Luc Brunel by Jane Doe (Attachments: # 1 Exhibit A, # 2 Exhi
# 2 Exhibit B)(Edwards, Bradley) (Entered: 05/17/2010) 548 REPLY to Response to Motion re 536 MOTION for Protective Order Regarding Deposition of Story Cowles and Incorporated Memorandum of Law RE Deposition of Story Cowles filed by Jane Doe II. (Goldberger, Jack) (Entered: 05/17/2010) 549 Unopposed MOTIO
Entities connected to both Jean-Luc Brunel and Story Cowles

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLeon Black
PERSONDarren Indyke
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSONLarry Visoski
PERSONMaria Farmer
PERSON
United States
LOCATION
Les Wexner
PERSON