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couldn't really communicate, saying that they are the "easiest" girls to get along with. My assumption was that Jean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls for Epstein). They were young and European looking and sounding. 45. Afterwards we all had dinner by the
present that interest. Among the interests that satisfy these criteria are injury to reputation. Sackniani. Liggett Grp., Inc., 167 F.R.D. 6, 20-21 (E.D.N.Y. 1996) (citing Penthouse Intl. W.I. Playboy Enterprises, Inc.. 663 F.2d 371, 373, 392 (2d Cir. 1981)). The burden of demonstrating an interest relat
ptember 3, 2008 VIA COURIER Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear By virtue of this letter, the United States Attorney's Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. On June 30, 2008, Jeffrey Epstein (he
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein v
laws) the TVPA up to and following the return of an indictment against Epstein on or about July 8, 2019. On or about that date, the U.S. Attorney's Office for the Southern District of New York indicted Epstein (and unnamed "associates") for violating the TVPA. Later, on or about July 29, 2020, the same Office indicted Epstein's co-conspir
couldn't really communicate, saying that they are the "easiest" girls to get along with. My assumption was that Jean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls for Epstein). They were young and European looking and sounding. 45. Afterwards we all had dinner by the
mber 3, 2008 VIA COURIER Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VICTIM Dear • By virtue of this letter, the United States Attorney's Office for the Southern District of Florida provides you with the following notice because you are an identified victim of a federal offense. On June 30, 2008, Jeffrey Epstein (he
gave $1 million around the same time that Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas—often from Eastern Europe and South America—are known to have been passengers on Epstein’s private jets. The U.S. Attorney General’s Office in Florida says that it is against
e FBI began investigating allegations that wealthy investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The U.S. Attorney’s Office for the Southern District of Florida accepted Epstein’s case for prosecution, and the FBI] issued victim notification letters to my two clients, minors Jane Doe No. | and Jane
reign commerce between the United 23 EFTA00162143 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 24 of 130 States and Europe, especially Eastern Europe. 88. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
anently labeled a "Registered Sex Offender," and was jailed in 2008. Epstein also entered into a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida barring his prosecution (and prosecution of his known and unknown co-conspirators) for violations of the TVPA and other sex offenses in
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein
to engage in commercial sex acts and in other ways. 472. As outlined above, the United States Department of Justice (including the U.S. Attorney's Office for the Southern District of New York and the U.S. Attorney's Office for the Southern District of Florida) was investigating Epstein's federal criminal liability for violating (among ot
York, Florida, New Mexico, New Jersey, Massachusetts, the U.S. Virgin Islands, and elsewhere, and in foreign commerce to places abroad, especially Eastern Europe. 121. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
imes against dozens of young women and girls, some as young as 14 years old. With respect to the specific discoveries, the United States Attorney's Office for the Southern District of Florida found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 100 times or more." 43. As a consequ
Entities connected to both Eastern Europe and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSON
George W. Bush
PERSONLeon Black
PERSONSouthern District
LOCATION
New York
LOCATION
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSONWeiss
PERSON