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nt: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, au
resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, au
EOUEST NO. 6 All documents relating to communications with any of the following individuals from 1999 — resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, audio tapes, photographs or any other print or electronic media relating to females under the age of
REQUEST FOR PRODUCTION OF DOCUMENTS To DEFENDANT OHISLAINE MAXWELL via Email to the following counsel of record. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10m Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] /s/ Sigrid S. McCawley S
UMENT REQUEST NO. 26 (Directed to All Defendants) All documents relating to communications with any of the following individual from 1999 — present: Jean Luc Brunel and 9 EFTA00793333 DOCUMENT REQUEST NO. 27 (Directed to All Defendants) All video tapes, audio tapes, photographs or any other print or electron
ollowing individual from 1999 — present: Jean Luc Brunel and 9 EFTA00793333 DOCUMENT REQUEST NO. 27 (D
he following individual from 1999 — present: Jean Luc Brunel and 9 EFTA00793333 DOCUMENT REQUEST NO. 27 (D
T FOR PRODUCTION OF DOCUMENTS To DEFENDANTS via Email to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Counsel for Ghislaine Maxwell Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHN
2010 Dep. Tr. p.21 d Q. All right. All right. Ms. would you agree with me that there was an agreement between Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and to bring in girls from out of state that were underage? THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amend
ween Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and to bring in girls from out of sta
between Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and to bring in girls from out of sta
onically filed the foregoing document with the Clerk of Court by using the CM/ECF system. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: Copies of this filing were also provided by e-mail to: Marty Weinberg, coun
of underage girls." Id. In the joinder motion, also alleged she was "forced" to have sex with Harvard law professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Pr
professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
aw professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
HE SUPERSEDING INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA0009737
conditions she has proposed. " Any incentive Ms. Maxwell might have to flee to Fiance has been greatly diminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See. e.g.. France Derails Modeling Agent in Jeffrey Epstein I
ished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
iminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York,
Entities connected to both Jean-Luc Brunel and MORGAN & FOREMAN

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONLeon Black
PERSONDarren Indyke
PERSONJane Doe
PERSON
United States
LOCATIONJack Goldberger
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
John F. Kennedy
PERSONthe Southern District
LOCATION
Alfredo Rodriguez
PERSON
Richard Kahn
PERSON