Epstein Secrets

ND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to a

d in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would

d be 7 intimate with in addition to being the girlfriend of 8 Jeffrey Epstein? 9 A. No. 10 Q. Do you know somebody by the name of Jean 11 Luc Brunel? 12 A. Yes. 13 Q. How do you know him? 14 A. He was in the house like, I guess, a few 15 times. 16 Q. When? 17 A. When? 18 Q. Whe

e 19 of 20 Page 168 1 A. No. She was a guest, I assume. 2 Q. Any reason why there would be an overlap 3 between her staying at the house and Jean Luc 4 staying at the house, or it was just coincidence as 5 far as you could tell? 6 A. I don't know. 7 Q. Okay. And is there anywhere where yo

exual purposes, relevant issues not yet admitted by Defendant Epstein. Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for d

—Original Message— From: Tama Beth Kudman <[email protected]> Dale: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos are cancelled for now. A letter confining this is being >Sent out today. We have no idea ho

onday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos

Dale: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos

e: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos

—Original Message— From: Tama Beth Kudman <[email protected]> Dale: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel CjeanlucfPgmailcorn> Subject: Re: Hi >All depos are cancelle

ge 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Than

bject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be

Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be

EFTA_R1_01464813 EFTA02406993 Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my

-—-Original Message— From: Tama Beth Kudman <[email protected]> Date: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <[email protected]> Subject: Re: Hi >All depos are cancelled for now. A letter confirming this is being >Sent out today. We have no idea how long

onday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <[email protected]> Subject: Re: Hi >All depos

e: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <[email protected]> Subject: Re: Hi >All depos

-—-Original Message— From: Tama Beth Kudman <[email protected]> Date: Monday, November 16, 2009 at 7:48 PM To: Jean Luc Brunel <[email protected]> Subject: Re: Hi >All depos are cancelled

On March 10, 2010 Plaintiff filed her Motion for an Order to Show Cause and for an Order to Compel [DE 483] requesting entry of an Order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an Order compelling Jean Luc Brunel to

position. Plaintiff's counsel recently obtained Epstein's probation file that contains documents that further corroborate Plaintiff's position that Brunel has not remained out EFTA01660111 Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 2 of 4 CASE NO: 08-CV-80119-MARRA/JO

Show Cause and to Compel the Deposition of Jean Luc Brunel [DE 483]. On March 10, 2010 Plaintiff filed her

my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Thank you Sent from my iPhone Tama Beth Kudman On Jan 25, 2010, at 3:22 PM, Beth Williamson < wrote: Dear Ms. Kudman: My name is Bcth. I am assisting Brad Edwards in the Epstein matters. I jus