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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
Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein’s house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein’s friend. He elaborated that Mr. Brunel
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
e Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein's house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein's friend. He elaborated that Mr. Brunel ha
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
age minors from 24 the authorities? 25 MR. PIKE: Form. 0121 1 A. I refuse to answer. 2 Q. As an employee of Jeffrey Epstein did you know 3 Janusz Banaziak? 4 A. I refuse to answer. 5 MR. PIKE: Form. 6 Q. Was Janusz Banaziak also an employee of 7 Jeffrey Epstein? 8 MR. PIKE: Form. 9 A. I refu
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
ar, like I said, there's going to be many, many, many message pads, I have not counted them, but a lot created by either yourself or someone named Janusz Banaziak or , Alfredo Rodriguez, , , various people that we know to have been employed at Jeffrey Epstein's home. And it seems that on one particular day
Entities connected to both Jean-Luc Brunel and Janusz Banaziak

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Bill Clinton
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Les Wexner
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
John F. Kennedy
PERSON
Ehud Barak
PERSON
Sarah Kellen
PERSON
Scarlett Johansson
PERSON
Glenn Dubin
PERSONNadia Marcinkova
PERSONEva Andersson-Dubin
PERSON