Epstein Secrets

ld him about my abuse and trafficking by Epstein. I also told him at that time that I had been sexually abused by Prince Andrew, Ghislaine Maxwell, Jean Luc Brunel, Alan Dershowitz, and other powerful people. 50. In around April 2011, as a follow-up to my earlier call with Brad Edwards, I got a telephone call

's inner circle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc Brunel many times. Brunel was another of Epstein's closest friends and a regular traveling companion, who had many contacts with young girls throug

ircle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc Brunel many times. Brunel was another of Epstein's closest friends and a regular traveling companion, who had many contacts with young girls throughout the

abused by Prince Andrew, Ghislaine Maxwell, Jean Luc Brunel, Alan Dershowitz, and other powerful people. 50.

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

ust 16, 2010. See Edwards Dec. at ¶ 6-7. 17. Maxwell was not the only important witness to lie to avoid deposition by Edwards in the Jane Doe case. Jean Luc Brunel did so as well. Upon review of message pads police took from Epstein's home, many were discovered to be from Jean Luc Brunel, a French citizen and

ssage pads police took from Epstein's home, many were discovered to be from Jean Luc Brunel, a French citizen and one of Epstein's closest friends. Brunel left messages for Epstein that were taken by Epstein's staff such as "Ile has a teacher for you how to speak Russian. She is 2x8 years old not blon

deposition by Edwards in the Jane Doe case. Jean Luc Brunel did so as well. Upon review of message pads poli

al place of abode with Mark, a person of suitable age and discretion who resides there . . . ." 8. The foregoing service constituted proper service the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 4(e)(2)(B). Under the Federal Rules of Civil Procedure, an answer to a properly served complaint must be filed withi

with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexu

others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexu

gs to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI determined that Epstein

we are also writing to ask for your non-opposition to Jane Doe No. 3 and Jane Doe No. 4's motion to intervene in the case. As you know, Rule 24 of the Federal Rules of Civil Procedure allows intervention on two grounds: Mandatory intervention is allowed where a putative intervenor "claims an inter relating to the . . .

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

ntiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, S

nts relating to, and all media depicting, any of the following individuals from 1999 — present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18. (a/k/a 11. All Documents relating to any agreements (including by not limited to confidentiali

Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18

or, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18

slaine Maxwell, Defendant. NOTICE OF SERVICE OF RULE 45 SUBPOENA DUCES TECUM UPON JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil Procedure, Plaintiff, hereby provides Notice of Service of Subpoena upon Jeffrey Epstein. A copy of the Subpoena is attached to this Notice as Exh

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

ntiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendants. The responses are due at the offices of Boies Schiller Flexner LLP, 575 Lexington Avenue, 7th Floor, New York, NY 1002

Epstein was involved with Eastern European women in particular and that a modeling agency he helped develop with his friend and known sexual abuser, Jean Luc Brunel, brought "young girls . . . often from Eastern Europe" to the U.S. on Epstein's private jets. 213. At all times material hereto, JP Morgan was awar

ual abuser, Jean-Luc Brunel, a French model scout who had suffered public disgrace for serial sexual abuse of young females. 136. Epstein enlisted Brunel to recruit new victims from all over the world, enticing them with promises of modeling careers before sexually abusing and trafficking them throug

is next target, another known sexual abuser, Jean-Luc Brunel, a French model scout who had suffered public di

e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r

ions that Epstein was involved with Eastern European women in particular and that a modeling agency he helped fund along with a known sexual abuser Jean Luc Brunel brought "young girls ... often from Eastern Europe" to the U.S. on Epstein's private jets. 197. By the time Deutsche Bank onboarded Epstein and du

ed fund along with a known sexual abuser Jean Luc Brunel brought "young girls ... often from Eastern Euro

helped fund along with a known sexual abuser Jean Luc Brunel brought "young girls ... often from Eastern Euro

ther Class Members. 313. This action has been brought and may properly be maintained as a class action against Deutsche Bank pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is readily and easily ascertainable from D