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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
assertion of the Fifth Amendment privilege ..." United States v. Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Basler v. Palmigiano, 425 U.S. 408, 318 (1976) ("the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to testify in
pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pa
g her vagina, inserting his fingers and civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule “is both logical and utilitarian.
Page: HOUSE_OVERSIGHT_010567 →tion by Edwards. Upon review of the.message pads that were taken from Epstein’s home in the police trash pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pals. He left messages for Epstein. One dated 4/1/05 said, “He has a teacher for you to teach you how
Page: HOUSE_OVERSIGHT_010589 →id adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); Accord, Vasquez v. State, 777 So. 2d 1200, 1203 (Fla. at 2001). The reason for this rule “is both logical and utilitarian.
Page: HOUSE_OVERSIGHT_013315 →tion by Edwards. Upon teview of the message pads that were taken from Epstein’s home in the police trash pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pals. He left messages for Epstein. One dated 4/1/05 said, “He has a teacher for you to teach you how
Page: HOUSE_OVERSIGHT_013343 →“EE.” In light of these circumstances of the case, this message reasonably suggested to 24 HOUSE_OVERSIGHT_013342 --- PAGE BREAK --- Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press reports reviewed by Edwards, B
Page: HOUSE_OVERSIGHT_013343 →pulls, see Exhibit “J” supra, many were from Jean Luc Brunel, a French citizen and one of Epstein’s closest pa
Page: HOUSE_OVERSIGHT_013343 →See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidenelne Jean Luc Brunel. (JLB) staying at his house during that relevant period of time attached Exhibit “JJ”. As a result, Edwards filed a Motion for Contempt, attached hereto as
Page: HOUSE_OVERSIGHT_013344 →Entities connected to both Jean-Luc Brunel and Palmigiano

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Donald Trump
PERSONJane Doe
PERSON
Bill Clinton
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONLarry Visoski
PERSON
United States
LOCATION
Les Wexner
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSON
Woody Allen
PERSON
Palm Beach
LOCATION
Virginia Giuffre
PERSON