Epstein Secrets

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

at Brunel was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein’s home by Epstein’s bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein’s house to the airport by Sarah Kellen. See deposition of Janusz Banaziak at page

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

at Brunel was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein's home by Epstein's bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein's house to the airport by Kellen. See deposition of Janusz Banaziak at page 154-1

South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people

e in South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people

Miles Alexander (South Africa) (Former managers of Little St. James estate) Cecelia Stein (Believed to be in South Africa) Valdson Cotrin (France) Jean Luc Brunel (France) 2 EFTA00098756 These are all people that may or may not cooperate during any criminal investigation. Inner Circle of Jeffrey Epstein —

tside Florida and Not Covered by the NPA "en Rinaldo Rizzo (New York) Former Employee of Glenn Dubin with knowledge of Epstein underage activity Igor Zinoview (Former Bodyguard in New York) Not loyal to E stein but may tip him off if approached out of fear of former employment obligation Andy Stewart (Fo

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

1/24/2009) 428 RESPONSE to Motion re (8 in 9:09-cv-81092-KAM) Third Party MOTION for Protective Order and Incorportated Memorandum of Law filed by Igor Zinoview. Replies due by 12/7/2009. Associated Cases: 9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 11/28/2009) 429 RESPONSE/REPLY to 422 Response in Oppo

ian Avenue Suite 1400 West Palm Beach , FL 33401 USA 561-202-6360 Fax: 561-835-8691 Email: [email protected] United States of America Amicus Jean Luc Bruhnel Material Witness Date 03/24/2009 1 03/24/2009 2 03/25/2009 3 03/26/2009 4 03/30/2009 5 04/28/2009 6 05/01/2009 7 05/04/2009 8 05/0

T.NET United States of America Amicus Jean Luc Bruhnel Material Witness Date 03/24/2009 1 03/24/200

rder to Show Cause and Compel Deposition of Jean Luc Brunel by Jane Doe (Attachments: # 1 Exhibit A. # 2 Exhi

11/28/2009 73 RESPONSE to Motion re (8 in 9:09-cv-81092-KAM) Third Party MOTION for Protective Order and Incorportated Memorandum of Law filed by Igor Zinoview. Replies due by 12/7/2009. Associated Cases: 9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 11/28/2009) 12/16/2009 74 OMNIBUS ORDER; denying as m

rine W. Ezell Bradley J. Edwards Deposition of Bill Riley Joint-privilege 03943-03945 09/18/2009 Adam Horowitz Jacquie Johnson Deposition of Jean Luc Bruhnel Joint-privilege 02911-02912 09/15/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privilege 02939 07/14/2009 Bradley J. Ed

n Katherine Ezell RE:Deposition of Jean Luc Bruhnel Joint W/P Priv. 15501.15555 09/18/2009 Jacquie

/P Priv. 06806-06807 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv. 06712 10/19/2009 Bradley Edwards Kikka Claudio RE: Igor Zinoview depo Joint W/P Priv. 06713.06714 09/15/2009 Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv. 11 EFTA00310058 Privilege Log— Date

levard Suite 400 West Palm Beach , FL 33401-2918 USA 561-842-2820 Fax: 561-253-0164 Email: [email protected] United States of America Amicus Jean Luc Bruhnel Material Witness Date 09/10/2008 1 09/10/2008 2 09/15/2008 3 10/03/2008 4 10/03/2008 5 10/03/2008 6 10/14/2008 7 10/20/2008 8 10/2

W.COM United States of America Amicus Jean Luc Bruhnel Material Witness Date 09/10/2008 1 09/10/200

11/28/2009 61 RESPONSE to Motion re (8 in 9:09-cv-81092-KAM) Third Party MOTION for Protective Order and Incorportated Memorandum of Law filed by Igor Zinoview. Replies due by 12/7/2009. Associated Cases: 9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 11/28/2009) 12/02/2009 62 Defendant's MOTION for Exte

n Katherine Ezell RE:Deposition of Jean Luc Bruhnel Joint W/P Priv. 15501.15555 09/18/2009 Jacquie

/P Priv. 06806-06807 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv. 06712 10/19/2009 Bradley Edwards Kikka Claudio RE: Igor Zinoview depo Joint W/P Priv. 06713-06714 09/15/2009 Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv. 11 EFTA00602845 Privilege Loa - Dat