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ition of Defendant in RTP 10 above. 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 the
s between Jeffrey Epstein and MC2 Models or Jean Luc Brunel, relating or referring to females coming into the
ent, unless otherwise stated) 7. All surveillance videos, slides, film, videotape, digital recording or other audio or video depiction or image of the Palm Beach Residence. Palm Beach residence is defined as the property located in Palm Beach, Florida having an address of 358 El Brillo Way, PB, FL 33480. I AM UNAWARE
. 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
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
. 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
ts are implicated. Request No. 7. All surveillance videos, slides, film, videotape, digital recording or other audio or video depiction or image of the Palm Beach Residence. Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to pr
No. 21 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
ts are implicated. Request No. 7. All surveillance videos, slides, film, videotape, digital recording or other audio or video depiction or image of the Palm Beach Residence. Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to pr
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
not identified in response to interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. No. 3. Identify all persons who came to the Palm Beach Residence and who gave a massage or were asked to give a massage to Defendant. No. 4. Identify all persons who came to the New York Residence and who gave a
. 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
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
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
. 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,
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
Entities connected to both Jean-Luc Brunel and the Palm Beach Residence

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSONJane Doe
PERSONJack Goldberger
PERSON
United States
LOCATION
Kenneth Marra
PERSON
Woody Allen
PERSONthe Southern District
LOCATION
Palm Beach
LOCATION
New York
LOCATION
Sarah Kellen
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSONNadia Marcinkova
PERSONSouthern District
LOCATION
Michael Jackson
PERSON
Jay Lefkowitz
PERSON
Santa Fe
LOCATIONRobert D. Critton
PERSON