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on by Edwards. Upon review of the message pads that were taken from Epstein's home in the police trash pulls, see Exhibit "3" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to teach you how
Jean Luc Brunel are attached hereto as Exhibit "EE." In light of these circumstances of the case, this message reasonably suggested to Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press reports reviewed by Edwards,
See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that relevant period of time attached Exhibit "JJ". As a result, Edwards filed a Motion for Contempt, attached hereto a
ulls, see Exhibit "3" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's closest pa
an provide explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7). 9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216. 10. Another of the minor girls Ep
did not notify E.W. and L.M. that a plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. about the plea. See id.
05, flight from CMH (Columbus, Ohio) to PBI (Palm Beach, Florida), indicate that in addition to Jeffrey Epstein, Sarah Kellen, Nadia Marcinkova, and Jean Luc Brunel, on board were three "females." The existence of these three "females" is conspicuously absent from the Rogers' logs. Compare Composite Exhi
motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded
t is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Epstein. The Court i
.B. Epstein, No. 502008CA037319XXXX MB AB, Depo. of Police Chief Michael Reiter at 80 (Palm Beac Cty. Cir. Ct. Nov. 23, 2009). 15 EFTA00191417 Brunel. In 2009, undersigned counsel (Brad Edwards, representing Jane Doe) served Jean Luc Brunel with a subpoena for a deposition before this court in Doe
z] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexually abused, correct? 26 Of course, in a proceeding such as this one, the victims are entitled to an i
acey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
stina ICitterman k. Dean Kretschmar 1. Michael Legamaro 16. All documents related to or referencing potential deponents in the Jane Doe, M. or E.W., cases used in connection with Investor meetings and/or general Investor solicitation into the Rothstein Ponzi Scheme. 17. Any employment agreemen
oquialism, discussion, conversation or agreement. C. "Plaintiff means =. (MI. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S1XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S8XXXXIVIB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case
with me or the witness. 6 A Fifth. 7 MR. GOLDBERGER: You're 100 percent 7 Q Is a modeling agency that he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go back to it. 9 right? 10 MR. GOLDBERGER: Absolutely. 10 MR. YAREMA: Object to the loan. 11 MIL E
he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go bac
that he is involved 8 correct. 8 in with Jean Luc Brunel; you know who that is MR. EDWARDS: Can we go bac
23 females? 24 MR. YAREMA: Object to the form. 25 A Fifth. 11 1 A I take the Fifth. 2 Q I represent a lady named, a young female 3 named E.W.; you know who that is, right? 4 Ma. YAREMA: Object to the form. S A The Fifth. 6 Q Jeffrey Epstein made you have sex with 7 E.W., didn't he?
ow Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in addition to your sexual interactions 19 Q Is that somebody who helped Jeffrey 20 with E.W., isn't it true that you have used 20 Epstein to devise the scheme to allow him access 21 strap-on dildos and vibrators on other underage 21 to
acey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
as g. Andrew Barnett 9 EFTA00722468 h. Bradley Edwards 15. All documents related to or referencing potential deponents in the Jane Doe,. or E.W., cases used in connection with Investor meetings and/or general Investor solicitatio the Rothstein Ponzi Scheme. 16. Any employment agreements or
D3 Capital Club, LLC c. Bill Clinton; d. Alan Dershowitz; e. David Copperfield; f. Kevin Spacey; g. Chris Tucker; h. Prince Andrew i. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-cv-61780-WJZ Document 25 Entered on FLSD Docket 12/17(2009
. Chris Tucker; h. Prince Andrew i. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. D
; g. Chris Tucker; h. Prince Andrew i. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. D
uialism, discussion, conversation or agreement. C. "Plaintiff means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051)COOME3), E.W. (E. W. v. Jeffrey Epstein, Palm Beach County Case #50200SCA028058XXXXMB), Jane Doe' (Jane Doe v. Jeffrey Epstein, United States District Court Case
acey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. D
oc 1063 Filed 10/13/10 Page 7 of 8 h. Bradley Edwards 15. All documents related to or referencing potential deponents in the Jane Doe, L.M. or E.W., cases used in connection with Investor meetings and/or general Investor solicitation into the Rothstein Ponzi Scheme. 16. Any employment agreemen
ate, Mark A AP44044,11 Lauren Brooke tang, Logan Brune Lang. Jesse Ha n al:Sang. Colton Ceases' J. M
th to do so today. "It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, E.W. has the right to have these documents unsealed," wrote former Circuit Judge Bill Berger, now in private practice and representing one of the women.
calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible eviden
ed to lead to the discovery of the admissible evidence; protected by privacy rights 07025-07027 10/29/2009 Bradley Edwards Paul Cassell ■. and E.W. v. Epstein — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide
Entities connected to both Jean-Luc Brunel and E.W.

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
George W. Bush
PERSONJane Doe
PERSON
Marc Rich
PERSONLeon Black
PERSONJack Goldberger
PERSON
Donald Trump
PERSONDarren Indyke
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
Joe Biden
PERSON
United States
LOCATION
Paul Cassell
PERSON