Epstein Secrets

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

Motion for Ruling on Service of Process on Jeffrey Epstein 9. Given the flagrant violations of Florida Statutes dealing with Service of Process, the Florida Rules of Civil Procedure, this Court's Order of October 5, 2016, and Plaintiffs attempt to mislead the court by not informing the court that there was opposition to his moti

o blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was forced to pursue other

ant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu

portant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu

issible discovery. The requested materials 15 EFTA00708307 Case 09-34791-RBR Doc 1603 Filed 04;08:11 Page 16 of 23 are not discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules. Moreover, the docu

MARRA/JO HNS ON 08080119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NON-PARTY, JEAN LUC BRUHNEL'S RESPONSE TO PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUS E AND FOR AN ORDER TO COMPEL AND 'NCO RPO RATED MEMORANDUM OF LAW Non-party Jean

e and for an Order to Compel and Incorporated Memorandum of Law which was filed on March 10, 2010. (DE#483). Plaintiff's counsel seeks to compel Mr. Bruhnel, a french citizen who is not a party to the instant action, to sit for a deposition that was canceled and for which he has never been re-noticed. T

e 3 of 6 Bruhnel's testimony abroad pursuant to Florida, Federal and International law. Indeed, undersigned counsel directed plaintiff's counsel to the Florida Rules of Civil Procedure and the Hague Convention, each of which provide specific mechanisms for the securing of testimony abroad. Plaintiff's counsel has never served Mr.

EFFREY EPSTEIN, Defendant. / NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be

22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has

EFFREY EPSTEIN, Defendant. / NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be

22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has