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October 19, 2017 Via eCourtesy The Honorable Rodney Smith Dade County Courthouse 73 West Flagler Street Courtroom DCC1401 Miami, FL 33130 RE: Jean-Luc Brunel, individually and MCI Model & Talent Miami, LLC vs. Jeffrey Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YLORG Case No.: 14-21348 CA 01 Dear Jud
Courtroom DCC1401 Miami, FL 33130 RE: Jean-Luc Brunel, individually and MCI Model & Talent Miami, LLC v
et Courtroom DCC1401 Miami, FL 33130 RE: Jean-Luc Brunel, individually and MCI Model & Talent Miami, LLC v
reet Pompano Beach, FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding
frey Epstein case. From my review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the Third District in HAUSER VS. SCHIFF, I have attached a copy of that case for your ready reference. It is now almost two years past the January 2015 filing date of
ervice of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it
Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it
ce Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it
et Pompano Beach , FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the
tein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the Third District in HAUSER VS. SCHIFF. I have attached a copy of that case for your ready reference. It is now almost two years past the January 2015 filing date of
land in the Caribbean. Florida's Third District Court of Appeal said service of the complaint by Miami-based MC2 Model & Talent LLC and its owner, Jean-Luc Brunel, on an office supervisor at Epstein's U.S. Virgin Islands business address did not comply with the requirements under Florida law and that the sui
Page: EFTA00010249 →and that the suit should be dismissed without prejudice, meaning it could be reified. The appeals court agreed with Epstein, who had argued that Brunel and MC2 never attempted to serve him at his primary residence, a private island called Little St. James in the U.S. Virgin Islands. "Brunel and MC
Page: EFTA00010249 →based MC2 Model & Talent LLC and its owner, Jean-Luc Brunel, on an office supervisor at Epstein's U.S. Virgi
Page: EFTA00010249 →e, according to the opinion. Brunel then tried the Virgin Islands business address, which the trial court deemed acceptable in September 2018. But the Third District said that in order for substitute service to be acceptable under Florida law, it must be made on an individual doing business as a sole proprietor
Page: EFTA00010250 →ay. Attorneys for Epstein did not immediately respond to a request for comment. Judges Kevin Emas, Edwin A. Scales RI and Norma S. Lindsey sat for the Third District. Epstein is represented by Scott J. Link and Kara Berard Rockenbach of Link & Rockenbach PA. Brunel and MC2 are represented by Joe Titone. The ca
Page: EFTA00010251 →Entities connected to both Jean-Luc Brunel and the Third District

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
United States
LOCATIONMaria Farmer
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
David Boies
PERSON