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T COURT OF APPEAL OF FLORIDA THIRD DISTRICT DCA CASE NO.: 3D18-1997 L.T. CASE NO.: 2014-021348 CA 01 JEFFREY EPSTEIN, Appellant/Defendant, vs. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, Appellees/Plaintiffs. REPLY BRIEF OF APPELLANT On Appeal from a Non-Final Order of the Circuit
REY EPSTEIN, Appellant/Defendant, vs. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC
JEFFREY EPSTEIN, Appellant/Defendant, vs. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC
Appellees/Plaintiffs. REPLY BRIEF OF APPELLANT On Appeal from a Non-Final Order of the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) LINK & ROCKENBACH, PA Counsel for Appellant 1555 Palm Beach Lakes Blvd.,
with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexua
gs to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI determined that Epstein h
others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexua
counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." The U.S. Attorn
others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own ea s
with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own ea s
gs to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own ea sexual gratification, but also for the sexual gratification of oth Epstein had committed dozens and
counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." The 7 EFTA002
SE NO.: 2014-021348 CA 01 RECEIVED, 11/5/2018 4:55 PM, Mary Cay Blanks, Third District Court of Appeal JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, Appellees/Plaintiffs. I ANSWER BRIEF OF APPELLEES/PLAINTIFFS On Appeal from a Non-Final Orde
ss, (in which his housekeeper answered the door) Epstein successfully moved to quash the service of process against him (Defendant's App. C, p.24). Brunel then requested leave to serve Epstein, which the trial court granted on October 5, 2016 (Defendant's App. E, p.48). The trial court gave Brunel 120
JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC
tiffs. I ANSWER BRIEF OF 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 joetitone708@
o blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was forced to pursue other
ant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu
portant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu
A CM/ECF and EMAIL) Broward County - Ann: Hollie N. Hawn, Esq. Government Center (VIA CM/ECF and EMAIL) Leon County Tax Collector (Via US Mail) Miami-Dade County Tax Collectors (VIA CM/ECF and EMAIL) Peter F. Valori, Esq. DAMIAN & VALORI LLP (VIA CM/ECF and EMAIL) Canon Financial Services Inc. (Via US Ma
IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL Civil Action No.: 14-21348 CA 01 (34) Plaintiff
OR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL Civil Action No.: 14-21348 CA 01 (34) Plaintiff
ND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL Civil Action No.: 14-21348 CA 01 (34) Plaintiff
n to Quash Attempted Service, before the Honorable Rodney Smith on June 22, 2016 at 9:00 ■. or as soon thereafter as the matter may be heard, at the Miami-Dade County Courthouse, 73 West Flagler Street, Room DCC 416, Miami, Florida 33130. PLEASE GOVERN YOURSELF ACCORDINGLY. Is/ Joe Titone Joe Titone Attorney
gs to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI determined that Epstein h
others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexua
with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexua
efense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the la telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." The U.S. Attorn
L SECTION 34 CASE NO. 2014-21348-CA-01 JEAN-LUC BRUNEL, individually; and MC2 MODEL & TALENT MIAMI, LL
CIVIL SECTION 34 CASE NO. 2014-21348-CA-01 JEAN-LUC BRUNEL, individually; and MC2 MODEL & TALENT MIAMI, LL
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, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG, Defendants
TALENT MIAMI. LLC vs. JEFFREY EPSTEIN. TYLER McDONALD: and TYLER McDONALD d/b/a YLORG, 1 I th District Court Case No. 2014- 21348-CA-01, in and for Miami-Dade County, Florida ("the Action"). It is understood and agreed that this settlement is the compromise of a doubtful and disputed claim, and that the payment
was auctioned off. In 2003, we reported that Epstein, who's been described as "a connoisseur of beautiful women," was talking to Karin Models owner Jean-Luc Brunel about doing a deal, but it went nowhere. Epstein has also met with Elite's Gerald Marie and 1 Management's Scott Lipps. Now we hear Epstein has bee
omen," was talking to Karin Models owner Jean-Luc Brunel about doing a deal, but it went nowhere. Epstein
ul women," was talking to Karin Models owner Jean-Luc Brunel about doing a deal, but it went nowhere. Epstein
Cuba must stay in Miami-Dade schools, judge rules By LAURA WIDES-MUNOZ 7heAssociatedPrtss MIAMI - A federal judge Monday temporarily barred the Miami-Dade County School District from remov- ing a children's book about Cuba from school libraries and in a strongly worded opinion ordered the district the ser
h, Epstein violated Florida State Statute, 837.02 Perjury in official proceeding, therefore committing a felony. COUNT #8 Do you know a man named Jean Luc Brunel? EPSTEIN: Can you spell it? He was at your house last week, does that remind you? a l Form, move to strike, culation, argumentative, harassing.
MR. Yes. Do you know him? EPSTEIN: Can you spell his name for me, please? I don't need to spell his name. Do you know who I'm talking about, Mr. Brunel? EPSTEIN: Sony, Mr. what? EFTA01695647 B-r-u-n-e-1. EPSTEIN: I would like to answer that question as well, but my attorneys have counseled me t
felony. COUNT #8 Do you know a man named Jean Luc Brunel? EPSTEIN: Can you spell it? He was at your hous
r 15, 2009, he testified to this flight. He stated that he flew Jeffrey Epstein and via helicopter leaving the county of Palm Beach and landing in Miami-Dade County, Florida. The pilot left Epstein and n Miami, and it was unknown to him when or how they returned to Palm Beach. Jeffrey Epstein, left the county,
Entities connected to both Jean-Luc Brunel and Miami-Dade County

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Donald Trump
PERSONJane Doe
PERSON
United States
LOCATION
Bill Clinton
PERSON
Joe Biden
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
George W. Bush
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONLarry Visoski
PERSON