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o, she didn't live there. 23 O. What about Joan Luc Brunel? 24 A. No. 25 O. How about: Did Mark Epstein
, so 9 grabbed the wrong door, but that's actually the only 10 thing that sticks in mind was that ono. 11 Q. Have you ever done any research on Jean Luc 12 Brunel? 13 A. No. 14 Q. Do you have any idea that he's known is throughout Europe as somebody who has sex with underage 16 girls/ 17 A
when I was - about the 20 time when I was leaving. 21 O. What about Ghislaine Maxwell? 22 A. No. no, she didn't live there. 23 O. What about Joan Luc Brunel? 24 A. No. 25 O. How about: Did Mark Epstein ever indicate to 106 1 O. Did he ever mention a brother that he may have 2 to you? 3 A. I met
ed the wrong door, but that's actually the only 10 thing that sticks in mind was that ono. 11 Q. Have you ever done any research on Jean Luc 12 Brunel? 13 A. No. 14 Q. Do you have any idea that he's known is throughout Europe as somebody who has sex with underage 16 girls/ 17 A. No. la O
5 act. FL 33401 Plaintiff. I 6 /Case No. 5020006020051 On behalf of the Defendant by telephone: IX/WM AD JRFPRRY DITHER. e BURMAN. CRITTON. LUTTIER & COLEMAN Defendant . I 9 BY: MICHAEL J. PIKE. ESO.. 515 N. Fla or Drtve DEPOSITION OF 10 Suito 400 lm ad,. FL 33401 LARRY MAUNA NORAISON 11 TAKEN
181534 Mark Epstein September 21, 2009 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 24 M. Epstein Jean Luc Brunel? A. No. Q. How often are you at the property at 301 East 66th Street? A. I pick up my children there sometimes. Maybe -- well, actually, they ar
years old, would you let them alone with him? MR. COHEN: Objection. MR. CRITTON: Form. A. Yes, I would. Q. Do you know anything about Jean Luc Brunel? A. I never heard the name before. You just mentioned it before. Q. Are you familiar with the modeling agency MC Squared? A. No. Q. Do you know
re 13, 14 years old, would you let them alone with him? MR. COHEN: Objection. MR. CRITTON: Form. A. Yes, I would. Q. Do you know anything about Jean Luc Brunel? A. I never heard the name before. You just mentioned it before. Q. Are you familiar with the modeling agency MC Squared? A. No. Q. Do
19 20 21 22 23 24 25 24 M. Epstein Jean Luc Brunel? A. No. Q. How often are you at the property at
) RICHARD H. WILLITS, ESQ. Attorney for Plaintiff, 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 (via telephone) BURMAN, CRITTON, LUTTIER & COLEMAN, LLP Attorneys for the Defendant, Jeffrey Epstein 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 BY: ROBERT CRITTON, ESQ. (vi
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
d to this subpoena as directed. DATED this 16th day of April, 2010. BY: CRITTON, JR. ( ttorneys for Defendant Jeffrey Epstein) Burman, Critton, Luttier & Coleman 303 Banyan Blvd., Suite 400 est Palm Beach, FL 33401 . CRITTON, JR., ESQ. For the Court EFTA00725168 EXHIBIT A DEFINITIONS AND INSTRUCTIONS
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
Case 09-34791-RBR Doc 1603 Filed 04/08/11 Page 20 of 23 (VIA CM/ECF and EMAIL) (VIA CM/ECF and EMAIL) Robert D. Critton, Esq. Burman, Critton, Luttier & Coleman (VIA CM/ECF and EMAIL) Roth & Scholl Attn: Jeffrey C. Roth, Esq. Attorneys For Creditor Blue Capital Us East Coast Properties, L.P. (VIA CM/ECF
o. 2 v. Epstein Page 22 Request No. 19. Any and all documents reflecting or consisting of communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the United States from other countries to pursue a career in modeling, including, but not limited to,
tween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
s between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
ROB R D. C ITTON , ESQ. Florida Bar No. 22416 rcrit(bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeebcIclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561-842-2820 Fax: 561-515-3148 (Co-counsel for Defendant Jeffrey Epstein) 'Title 18.
Entities connected to both Jean-Luc Brunel and Luttier & Coleman

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