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. 2 v. Epstein Page 19 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,
etween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
ns between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
are unknown; or (2) where production would "implicitly authenticate" the documents. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976) (issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's
ating; rather, if anything, it is their contents, which are not protected by the Fifth Amendment privilege so long as they were created voluntarily. Fisher 425 U.S. at 410; see also In `Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness statements, and r
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
poena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence EFTA00222080 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009
t that the papers existed, were in his possession or control, and were authentic. United States v. Doe, 465 U.S., at 613, and n. 11, 104 S.Ct. 123T Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, 1487 U.S..'! at 104, 10
. 2 v. Epstein Page 19 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,
etween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
ns between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th
ubpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (61h Ed.). The priv
that the papers existed, were in his possession or control, and were authentic. United States v. Doe. 465 U.S., at 613. and n. 11. 104 S.Ct. 1237; Fisher. 425 U.S., at 409-410. 96 S.Ct. 1569; id. at 428. 432. 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States. [487 U.S..1 at 104, 108 S
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
f 22 documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's
redacted documents from Clipped research with Attachment to Subpoena NES, LLC; article titled "Working for Top Bosses on Wall St. Has Its Perks"; Jean-Luc Brunel research; Robert Maxwell; Jeffrey Epstein Leslie Wexner (file folder) Kastigar Letters (file folder) 2703 Motion & Order-Cingular (red file folder
Top Bosses on Wall St. Has Its Perks"; Jean-Luc Brunel research; Robert Maxwell; Jeffrey Epstein Leslie
for Top Bosses on Wall St. Has Its Perks"; Jean-Luc Brunel research; Robert Maxwell; Jeffrey Epstein Leslie
; 9/17/07 to Lekowitz; 10/25/07 Sloman Itr to Davis; 11/8/07 Lefkowitz to Sloman; 11/13/07 Sloman to Lefkowitz (was this sent?); 11/28/07 Starr to Fisher; 11/29/07 Starr to Acosta; 11/30/07 Acosta to Lefkowitz; 12/4/07 Acosta to Starr; 12/5/07 Starr to Acosta; 12/6/07 Sloman to Lefkowitz; 12/7/07 Sanc
9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/2007 Subpoena to Eric Gany (return date 9/11/07) 8/17/2007 M
urn date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr
(return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr
d ready to unwind the Agreement. B-10 11/30/2007 Kenneth Starr Alex Acosta Letter in response to 11/28/2007 letter to Assistant Attorney General Fisher. Outlines the history of negotiations with various counsel for Epstein illustrating how the Non-Prosecution Agreement was reached. Request to prov
fund friend Glenn Dubin, MC2 Models founder Jean-Luc Brunel, and on occasions former Israeli Prime Minister
ncier. It was alleged that young girls were recruited from Brazil and other South American countriesfcformer Soviet countriesrand Europe, and that Jean-Luc Brunel's "MC2" modeling agency was also supplying girls to EnteaL25,1Eallii.921 Epstein's 2006 mugshot In May 2006, Palm Beach police filed a probable cause
d some of his workers, including his pilot, housekeeper and office work staff, in the apartment complex. Epstein has also housed underage girls, who Brunel scouted for his MC2 modeling agency.tsolisij On August 6, 2012, a model and party promoter associated with MC2, Pedro Gaspar, who lived above anoth
Le was announced on 26 June 2014 as the next Governor of South Anstralia to replace Kevin Scarce.,451 Following the death erguch; Labor won the 201 Fisher by-election by nine votes from a 7.3 percent two party swing in a hotly contested three- cornered contest. Wea.ffierrn nonetheless kept Brock and Ha
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA (West Palm Beach) LM v. Espstein PLAINTIFF: LM DEFENDANT: Epstein, Jeffrey WITNESS: Jean Luc Bruhnel Material DOCKET CASE NUMBER: 9:09cv81092 FILING DATE: 7/24/2009 JURISDICTION: Federal Question JUDGE: Marra, Kenneth A NATURE OF SUIT: 360 Perso
M DEFENDANT: Epstein, Jeffrey WITNESS: Jean Luc Bruhnel Material DOCKET CASE NUMBER: 9:09cv81092 FILING
gel, Martin & Heilbrun; McDermott, Suzanne; Martin, Christopher H; John Does 1 Through 10; Heilbrun, Robert; Gerzog, Lawrence D; Fisher, Ivan; Fisher, Diane DBA the Fisher Group; Fisher & Soffer AKA Fisher & Sophir; Epstein, Jeffrey E; Ellyn Bank; Cohen, Debra Elisa COUNTER-CLAIMANT: Fisher, I
se Siegel; Siegel, Martin & Heilbrun; McDermott, Suzanne; Martin, Christopher H; John Does 1 Through 10; Heilbrun, Robert; Gerzog, Lawrence D; Fisher, Ivan; Fisher, Diane DBA the Fisher Group; Fisher & Soffer AKA Fisher & Sophir; Epstein, Jeffrey E; Ellyn Bank; Cohen, Debra Elisa COUNTER-CLAI
okkeeper for Mc2, owned by Epstein associate Jean-Luc Brunel. He employed scouts in South America, Europe and
Maritza Vasquez, who was later interviewed in New York by an FBI agent from Miami. Vasquez worked as a bookkeeper for Mc2, owned by Epstein associate Jean-Luc Brunel. He employed scouts in South America, Europe and the former Soviet Union to find him models to bring to the United States, Vasquez said in a 2010 swo
t 301 E. 66th St. in New York, a building purportedly owned by Epstein, the deposition said. Epstein didn’t charge the girls rent, Vasquez said, but Brunel charged them $1,000 a month, with four of them at a time sharing one apartment. The girls who were the youngest and most beautiful stayed at the 66th
of the deputy consul general of Iran to attorney Ivan Fisher and others. Epstein paid $15,000 a month in rent to the State Department, but he charged Fisher and his colleagues $20,000. Though the exact terms of the agreement are sealed, the court ruled against Epstein. Wexner offers some insight into his
9/4/07) 8/16/2007 Subpoena to Adam Perrylang (return date 9/4/07) 8/16/2007 Subpoena to Lesley Groff (return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harry Beller (return date 9/11/07) 8/16/2007 Subpoena to Eric Gany (return date 9/11/07) 8/17/2007 M
urn date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr
(return date 9/4/07) 8/16/2007 Subpoena to Jean-Luc Brunel (return date 9/4/07) 8/16/2007 Subpoena to Harr
ready to unwind the Agreement. B I() 11/30/2007 Kenneth Starr Alex Acosta Letter in response to 11/28/2007 letter to Assistant Attorney General Fisher. Outlines the history of negotiations with various counsel for Epstein illustrating how the Non-Prosecution Agreement was reached. Request to prov
Entities connected to both Jean-Luc Brunel and Fisher

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