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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
des, whether 19 that -- I know you said that he spends some time in 20 Miami, but whether he primarily resides in Miami or 21 New York or Antartica, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this gentleman Jean
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
y resides, whether 19 that -- I know you said that he spends some time in 20 Miami, but whether he primarily resides in Miami or 21 New York or Antartica, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this gentleman Jean Luc 25 Brunel at
ut I don't know who he is. 11 Q. Did you hear his name from Jean Luc Brunel 12 or Mr. Epstein? 13 A. No. 14 Q. Okay. So, other then seeing Jean Luc 15 Brunel at the house last week and talking with 16 Mr. Epstein by the pool or by the cabana or around 17 the house, did you make any other ob
known, just based on your to have girlfriends? And by girlfriends that she would be in addition to being the girlfriend of Epstein? No. Do you Luc Brunel? A. Yes. Q. How do A. He was times. Q. A. Q. A. Q• a Tuesday. know somebody you know him? by the name of Jean in the house like, I g
p from the airport, safe 24 assumption? He didn't just drive to the airport. 25 (A discussion was held off the record.) Yes. All right. Did Mr. Brunel bring any with him? No. It was him alone? Yes. How did he get to the house? I think he has been picked up by Igor at this (561) 832-7500 PROS
nt to pick him 5 6 up. Q. Okay. It wouldn't be 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 airport and took him to the house? 12 A. Right. 13 Q. Do you know what car he took to pick him 14 up? 15 A
y resides, whether 19 that -- I know you said that he spends some time in 20 Miami, but whether he primarily resides in Miami or 21 New York or Antartica, you have no idea? 22 A. No. 23 Q. Okay. Other than last week, when was the 24 last time that you saw this gentleman Jean Luc 25 Brunel at
Entities connected to both Jean-Luc Brunel and Antartica

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Sarah Kellen
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONKudman
PERSONJack Patrick Hill
PERSONStory Cowles
PERSONIgor Zinoview
PERSON
Stanford University
LOCATIONJanusz Banaziak
PERSONIsidro Manual Garcia
PERSONBanaziak
PERSON