3
Shared Docs
3
Same-Page
11 / 3
Mentions
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
0, 2015. The required Notice of Service was never filed with the Court in respect of that attempt, which you, yourself, conceded in your later filed Motion for Reconsideration was improper service. After rescheduling the hearing on Mr. Epstein's April 29, 2015 Motion to Quash four separate times, you failed to appear at th
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
March 10, 2015. In that attempt the required Notice of Service was never filed with the Court, and which you, yourself, agreed in your later filed Motion for Reconsideration was an improper service. After rescheduling the hearing on Mr. Epstein's Motion to Quash, filed on April 29, 2015, and on four different occasions,
king detailed information relating to Epstein's air travel, aircraft used and flight manifests, all communications with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the United States from other countries and his personal calendars and schedules, could reveal the avai
ations with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the
unications with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the
e 5 of 8 the objection 'so general and sweeping in nature" that they aamount[ed] to a blanket assertion of the privilege: Id. p.11. In the instant Motion for Reconsideration, Epstein has set forth additional facts and detailed reasoning successfully demonstrating how forcing him to answer these requests would realistica
Entities connected to both Jean-Luc Brunel and Motion for Reconsideration

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONLeon Black
PERSONJane Doe
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
United States
LOCATIONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSONSouthern District
LOCATIONRoy Black
PERSONScott Rothstein
PERSON
Jay Lefkowitz
PERSON