Epstein Secrets

communications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into t

cations between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming

tween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the

nications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into t

designed to guarantee." Hoffman, 341 U.S. at 479. The United States Supreme Court has made clear that the scope of the Fifth Amend

See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that relevant period of time attached Exhibit "D". As a result, Edwards filed a Motion for Contempt, attached hereto as

ulls, see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's closest pa

on 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

Jean Luc Brunel are attached hereto as Exhibit "BE." In light of these circumstances of the case, this message reasonably suggested to 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,

sponsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845 Case 9:08-cv-80736-KAM L,,,,ument 291-10 Entered on FLSD 01/21/2015 Page 3 of 7 Edwa

rmation (e.g .. documents reflecting Epstein's air travel, aircraft used and flight manifests, all communications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into the United States from other countries and his personal calendars and schedules) that could reveal

ations with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into

unications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into

ein to walk a thin line with regard to "surrender[ing] the very protection which the privilege is designed to guarantee." Hoffman, 341 U.S. at 479. The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege also encompasses the 10 Case 9:08-cv-80119-KAM Document 391 Entered on FLSD D

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

ld support a criminal conviction, but even if "the responses would merely 'provide a lead or clue' to evidence having a tendency to incriminate."). The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege also encompasses the circumstance where "the act of producing documents in response

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

ion testimony. An analogy can be made to cases involving impermissibly suggestive showups.3 See e.g. Neil v. Biggers, 409 U.S. 188 (1972). In Neil, the United States Supreme Court, addressing suggestive showups, noted that the primary evil to be avoided is a very substantial likelihood of irreparable misidentification." Id. a

pstein will answer your questions, and o22200 16 then, you know, not -- not getting information, Maxwell 022203 17 evading the deposition. 022206 18 Jean Luc Brunel was another person who seemed o22200 19 to be very much involved in -- in trafficking the girls, o2z2210 20 and it was the same situation. A depositi

swers, you know, who is involved, which 022216 22 girls are involved, what are their names, what's -~ 022217 23 what's going on? o2:22:18 24 And so Brunel's deposition is set and then 022223 25 he -~ he finagles out of it too. I don't recall exactly ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 29 of 38

022203 17 evading the deposition. 022206 18 Jean Luc Brunel was another person who seemed o22200 19 to be ver

tially determined who was going to be President of the most powerful country in the world. There were two attorneys who argued that case in front of the United States Supreme Court, and arguing for the Democratic Presidential Candidate, Al Gore, was David Boies. He had put his credibility on the line in arguing the Bush versus