[2] IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAM-DADE COUNTY, FLORIDA. (9) IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA. DIVISION &) CML LJ DISTRICTS Ci OTHER PLAINTIFF{(S} CIVIL ACTION SUMMONS (b) Form for Personal Service on a Natural Person VS. DEFENDANT(S) JEAN-LUC BRUNEL JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A YLORG THE STATE OF FLORIDA:TO EACH SHERIFF OF THE STATE, YOU ARE COMMANDED to serve this Summons and @ Copy of (ha Com this lawsull on defendant: To Oefendani(s): JEFFREY EPSTEIN Address: (61 Pe oy Of e 423 fe 358 El Brillo Way Palm Beach, FL 33480-4730 IMPORTANT 4 Ato | A lawsuit has been fled against you. You have 20 calendar days after this summons is served on you to fila a written response l@ the altached complaini with the clerk of this courl. A phone call will not Proteci you Your writien response, including the Gas® number given above and lhe names of the parties musi be fled if you want the courl to hear your side of the casa. If you do not fle your esponge time, you may tese lhe case, and your wages, money and property may thereafter be taken without further waming from the Court. 8 are other legal requirements. You may want to call an atlomey right away. tf you do nol know an atlomey, you may cail an atiomey eferra service or a legal aid office (listed in the phone book). if you choose to file 4 written response yourself, at the same lime you fle your written response wilh ihe Clerk of the Court, you m st also mail or lake a copy of your written response to the "Plaintifi/Plaintif's Atlomey” named below. The central location of the Clerk's offite is al the Dade County Courthouse. The address for the courlhouse, and branch locations are listed below for your convenience: DADE COUNTY COURT LOCATIONS Reom 100 11 East 61h Steal Hiateah, Flonda 33010 Address: 621 S.E. 5TH STREET, POMPANO BEACH, FL 33060 PlaintiffPlaintiff Atlomey JOE TITONE Florida Bar No. 203882 F ee HARVEY RUVIN CLERK OF COURTS DEPUTY CLERK AMERICANS WITH DISABILITIES ACT OF 1990 ADA NOTICE _ “If you are a person with a disability who needs any accommodation in orde participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the Eleventh Judicial Circuit Court’s ADA Coordinator, Lawson E. Thomas Courthouse Center, 175 NW 1° Ave., Suite 2702, Miami, FL 33128, Telephone (305) 349-7175; TDD (305) 349-7174, Fax (305) 349-7355 at least 7 days hefore our scheduled court appearance, or immediately upon receiving this notification if the ime before the scheduled appearance is less than 7 days; if you are hearing or |voice impaired, call 711.” Pe osds county Cournoume (05) [ocsepts cate Centar (20) Nonh Dado isos Center (23) Room 133 Room 103 Room 100 73 Weal Fiagler Street 5400 NW 22 Averme 15555 Biscayne Bhd. Mia, Florida 33130 Miami, Florkta 33142 North Miami Beach, Flastda 33160 [7] miami Basch district Court (24) (C covet Gates Bistnel Court (25) D7 seuth Dade Justice Center (28) Room 200 Room 100 Room 1200 1130 Washington Avenue 3100 Ponce Os Lean Bivd 10710 SW 241 Steel Mami Baath, Florida 33139 Com Gables, Flonda 33134 Marti, Floris 33180 (Fy tues Distnet (21) CLESCT. O70 Rev. 11/11 Clerk's web aciiress: www. miami-daderierk.com HOUSE_OVERSIGHT_011908

OEN LA CORTE DE CIRGUITO DEL UNDECIMO CIRCUITO JUDICIAL EN Y PARA EL CONDADO DE MIAMI-DADE, LA FL¢ O EN EL TRIBUNAL DEL CONDADO EN Y PARA EL CONDADO MIAMI-DADE, LA FLORIDA. DIVISION O CML {J OTRA DEMANDANTE(S) EMPLAZAMIENTO DE ACCION CIVIL (b) NOTIFICACION PERSONAL A PERSONA NATURAL VS. DEMANDADO(S) 4 Demandado(s): Usted ha sido demandado legalments. Tiena 20 dias, conlades a partir def recibo de esta notificacion, para conteslar la demanda adj esaiito, y presentarla ante este tribunal, Una Damada (elefenica no lo protegera. Si usted desea que ef Iribunal cnnsidera su defe a presentar su respuesta por escrito, incluyendo e/ numero del caso y los nombres de las partes IMeresadas. Si usted no contesia ta dei tiempo, pudiese perder el caso pordria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del|tni xisten otros requisites legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede fs una de las oficinas de asistencia legal (Legal Aid Office) o un servicio de referencia de abogados (Altomey Referral Service) que aparece Is guia telafonica. Sl desea responder a la demanda por su cuenta, al misma impo en que presenmla su respuesta ante el tibunal, debera usted enviar por comeo o entregar en la mano una copia de su respuesta a la persona denominada abajo como "PlaintiftPlaintiff's Attomey” (Demandante o Abdgade de! Demandante) y presentar su contestacion a la demanda al Secretario del Juzgado. La ubicacion central de la Oficina del Secrelaro epta en el edificio de la Corte del Condado de Dade. La direccion de la Corte, y de las sucursales aparecen en la lista siguiente para su convenienciq: LOCALIDAD DE LOS TRIBUNALES DEL CONDADO DE DADE IMPORTANTE 0 Bode County Courthouse (05) 0 seseph Caleb Center (20) OF North Dade Justion Canter (23) D7 retest Qusiriet (21) Roam 131 Roam 103 Room 100 Roum i100 73 Weal Flagler Strest 5400 NW 22 Avenue 15555 Biscayne Bivd. 11 Eexi 6th Street Miami, Florida 33430 Miami, Florida 33142 Nori Miura Beach, Planda 33180 Hisieah, Flanda 33610 (1 Mam Basch District Court (24) CO Cora) Gables District Court (25) OF) South Dade Justica Center (20) Room 200 Room 100 Rom 1200 1130 Washingten Avenue 3100 Ponce De Leon Bhd. 10710 SW 211 Streat Miaml Beach, Flonda 33139 Coral Gabieg, Florina 33134 Morn, Florida 33189 Demandante o Abogado dei Demandante Numero del Colegio de Abogados: EL ESTADO DE LA FLORIDA: A cada alguacil del Estado: Se je ordena que hagen entrega de esta notificacion yu copia de la demanda en este pleitc al demandado(s) mencionada aniba. HARVEY RUVIN Secretario del Tribunal del Condado Como Secretario Adjunta Ley para Estadounidenses con Incapacidades “Si usted es una persona minusyalida que necesita hacer arreglos para poder participar en este proceso, usted tiene derecho, sin gasto alguno, a que Se le provea cierta ayuda. Por favor péngase en contacto con el Coordinador de ADA en el Onceavo Distrito Judicial ubicado en el Lawson E. Thomas Courthouse Center, 175 NW 1st Ave] Sala 2702, Miami FI 33128, Teléfonos (305)349-7175; TDD (305) 349-7174, Fax (305) 349-7355 por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales; o inmediatamente después de recibir esta notificacién si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacita del oido o de la voz, llame al 7[1.” CLKICT. 070 Rev 11/11 HOUSE_OVERSIGHT_011909

C AU TRIBUNAL DU ONZIEME ARRONDISSEMENT JUDICIARE DANS ET POUR MIAMI-DADE, FLORIDE. (1 AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE MIAMI-DADE, FLORIDE. CONVOCARION D' ACTION CIVILE (b) LIVRA! ON PERSONNELLE A UNE PERSONNE PLAINTE(S) VS. GONTRE ACCUSE(S) A (AUX) ACCUSE(S): ADRESSE: Des poursuites judiciaires ont ete enterprises contre vous. Vous avaz 20 fours consecutifs a partir a de la date de I'assignation d Gilalion pour deposer une response ecrite a la plainte cijointa aupres de ca tribunal. Un simole coup de telephone est insoffisant pa VOUS proteger. Vous ates obliges de deposer votre response eécrite, avec mention du numero de dossier G-dessus e( du nom des barik nommees ici, si vous souhailez que le tribunal entende votra causa. Si vous na deposez pas aotre reponse ecite dare le relai requig risquez de perdire la cause ainsi que votre salaire, votre argent, e1 vos biens peuvent etre saisis par la suite, aucun preavis ulterlqur du tribunal. Iya d'autres obligations juridiques et vous pouvez requerir les services immediats d'un avocatl. Si vous ne connaissez pas d'g vous pourriez telephoner a un service reference d'avocais ou a un bureau d'assislance juridique (figuran! a fannuaire de telephones). Si vous chotsissez de deposer vous-meme une reponse ecrite, il vous faudea egalement, en meme temps que cette formalite, faire pa expedier une copia de votre reponse ecrite au "Plaintif/Plaindifs Allomey” (Ptalgnant ou 4 son avocal) nomme cidessous et enregistreq volre reponse avec la Greffier du Tribunal, L'adresse centrale du bureau du Greffier esi la Dade County Courthouse. L'adresse du tribgnal,el adresse des succursales sont dans cifessous pour volre convenance ADRESSES DES TRIBUNALIX EN DADE C1 bade County Courthouse (05) 0 Joseph Caisb Canter (20) OO Nath Dade Justics Center (23) CO) Humes District (21) Reom 133 Room 103 Room 100 Room 100 73 Weal Flagler Street 5400 NW 22 Avenues 15555 Biscayne Blvd, 11 East 6th Stes Miami, Florida 33130 Miami, Porida 3142 North Miami Geach, Florida 23160 Hialeah, Florida 33010 OO Miami Beach Dntirict Coun (24) (1 Coral Gattes District Court (25) South Dade Jjustion Center (28) Ream 200 Room 100 Room 1200 1430 Washington Avenue 3100 Ponce De ian Biv. 40710 SW 211 Siren Miami Beach, Flonda 33739 Caral Gables, Flovida 33134 Mie, Florida 33189 Plainte/Avocat du Plainte Adresse: 7 Numero de barreau de la Floride: L'TAT DE LA FLORIDE: A chaque sherif de fetat vous etes oblige de presenter cette cilation el une photocpie de ia plainte ce document sur accuse (e) ci-desus. HARVEY RUVIN , DATE ON: Greffier de Tribunal TT ACT DE 1990 POUR AMERICAINS HANDICAPES AVIS DE I’ ADA “Si vous étes une personne handicapée qui a besoin d’accommodement pour pc participer 4 cette procédure, vous avez le droit, sans aucun coiit, d’avoir de |’aide 4| votre disposition. S’il vous plait contacter le Coordinateur de PADA du Tribunal de ’Ongi Circuit Judiciaire, Lawson E. Thomas Courthouse Center, 175 NW 1" Ave. Suite incapacité pour entendre ou parier, appelez le 711.” CLKICT. 070 Rev. 11/11 Clerk's web address: wanw,rmiamni-dadecterk.com HOUSE_OVERSIGHT_011910

CJ] NAN TRIBUNAL ONZYEM AWONDISMAN JIDISYE NAN E POU MIAMI-DADE COUNTY, FLORIDA. C] NAN TRIBINAL E POU TRIBINAL NAN MIAMELDADE COUNTY, FLORIDA. DIVIZYON O SIML O Lor PLENTIF(S) KONVOKASYON POU KA SIVIL (b) DELIVRE PERSONELMAN BAY YON MOUN Yo entre yon aksyon kont oumeum. Ou genyen 20 jou Kalandniye apres ou recevoi somasyon-an pou enregistre devan grefie tnbunal-sa, yon reponce pa ecri attache avec plentda. Yon apel pa telefon ka kapab prolege-ou. Se yon repente pa ecri,fo ou mete numero ka-a ki sou tet pagela avec nom moune-yo ki Sou papie-sa oblige ecri si ou vie ke iribunalta fende posilion-ou cou ka-a. Si ou pa enregistre reponce-ou a 'heure ou capab pedu ka-a san tribunal la pa anounce-ou er yen, ou capab pedu l'agen ou ak byen ou, Genyen lot demande, Ou ka besoin telefone yon avoka tout de suit. Si ou pa Joneh yon avoka, ou ka rele sevis ki rekomande avoka, ou biro ede legal (kinan lis liv telefone). Si ou shoisi voye yon reponce pa ecri oumenm, ou supose en mem tan poste en mem tan poste on pote on copi re: pa ecri pou avoka pleyan ov pleyan-yo ke non-li ama-a et enregistre reponce-la nan tribunala ki localize nan avek Sbkrete Tribinal, Adres santrat biwo Sekrete a se Dade County Courthouse. Adres tribinal la, ak adres lot tribinal yo nan lis ki nba a pou ou ka jwenn yo alez: ADRES TRIBINAL NAN DADE COUNTY CO Gade County Courthousa (05) 0 soseph Caieb Conter (20) OF North ade Justion Center (23) DF Hietesn District 21) Room 134 Room 103 Room 100 Room 100 73 Weal Flagler Street 5400 NW 22 Avenue 15555 Biscayne Blvd, 11 East tih Street Miara, Florida 23130 Miami, Florida 33142 North Migs Beach, Florida 33160 Hiajoah, Florida 33010 OD Mam Beach District Court (24) C1 Corsi Gattes Distinct Court (25) O south Dade Justicn Canter (26) Room 200 Roem 100 Reom 1200 1130 Washington Avenue 3100 Ponce De Laon Bivd 10710 SW 21 Steet Warn Beach, Flonda 33139 Coral Gables, Flofida 33134 Miomi, Florida 33189 Nimewo manm avoka a. Address: Plainle/Avocat du Plainie Numero de barreau de fa Floride: HARVEY RUVIN Sekrete Jenera! Tribinal La SEKRETE LWA 1990 POU AMERIKEN KI ENFIM ANONS POU AMERIKEN KI ENFIM “Si ou se yon moun ki enfim e ou bezwen akomodasyon pou ou patisipe nan pwosec ou gen dwa pou yo ba ou kék éd san ou pa gen pou ou peye. Silvouplé ko Kowddinaté ADA pou Tribinal Onzyém Distrik Jidisyé a nan: Lawson E. T Courthouse Center, 175 NW 1* Ave., Suite 2702, Miami, Fl 33128, Telefon (305} 349- 7175; TDD (305) 349-7174, Fax (305) 349-7355 omwen 7 jou anvan ou gen randevo pou ou parét nan tribunal la, oubyen imedyatman lé ou resevwa notifikasyon sa a si of gen mwens ke 7 jou pou ou parét nan tribunal la: si ifiki pale, rele 71 i> P “5 a’ ‘a; sl ou gen difikilte pou ou tande oubyen sa a, takte CLKICT. O70 Rev. 14/17 HOUSE_OVERSIGHT_011911

Filing # 22956396 E-Filed 01/26/2015 12:26:55 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC Civil Action No.: 14-21348 CA 01 Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YILORG Defendants. / AMENDED VERIFIED COMPLAINT FOR LEGAL & EQUITABLE RELIEF AND DAMAGES COME NOW the Plaintiffs, Jean-Luc Brunel and MC2 Model & Talent Miami, LLC, by and through undersigned counsel, and sues Defendants Jeffrey Epstein, Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable relief and defamation, and states as follows: 1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County, Plaintiff Jean-Luc Brunel resides in Dade County, Florida, and Piaintiff MC2 Model & Talent Miami, LLC, has an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. Ds Florida Statute 48.193(1)(a)(1) (‘long-arm”’) authorizes service on both out-of-state Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org). HOUSE_OVERSIGHT_011912

3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jean-Luc Brunel is the owner of Plaintiff modeling agency known as “MC2 Model & Talent Miami” (‘MC2”). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 5. Defendant Jeffrey Epstein (“Epstein”) is a hedge-fund manager with a residence in Palm Beach County, Florida. Defendant has been the subject of significant media coverage due to charges brought against him involving sexual contact with minors. (Composite Exhibit A attached). 6. Plaintiff Brunel and Epstein have known one another since the inception of Plaintiff MC2. Ts Plaintiff Brunel operated his modeling agency, Plaintiff MC2, without incident until Epstein was first charged in Palm Beach County with unlawful sexual contact with a minor in 2006. He was convicted of soliciting prostitution from a minor and sentenced to eighteen months in prison, of which he served thirteen months. He remains a registered sex offender in Florida as of this day. 8. First, after the initial criminal charges against Epstein were filed in Palm Beach County, Plaintiffs were widely implicated in the media as being “linked” to Epstein. These false stories caused both Plaintiffs a tremendous loss of business. a. Plaintiffs lost multiple contacts and business in the modeling business as a direct result of Epstein’s illegal actions. For example, several photographers will not work with MC2 due to the HOUSE_OVERSIGHT_011913

adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking Plaintiffs with those activities; namely, sex trafficking. (Composite Exhibit A). 10. One example of such a photographer was Michael Avedon, who worked with MC2 on photo shoots. Avedon stopped answering Plaintiffs’ emails and phone calls after having known Plaintiff for some time. Upon meeting Avedon out one night, Avedon stated to Plaintiff Brunel he had “found out some information” from some friends of his and that he could not associate his name with MC2. 11. This statement by Avedon was no doubt a reference to the alleged and false links between Plaintiffs and Epstein's illegal activities with under-aged girls. This incident clearly illustrates an example of lost business on Plaintiffs’ behalf. 12. | The second example of a business relationship that was terminated due to Epstein’s intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos Model Agency. The owner stated that the model to be placed with MC2 “found some article in internet, which changed her position and she preferred to be placed with another agency.” This was relayed to Plaintiff Brunel by e-mail dated October 15,2014. This amply demonstrates that Epstein’s intentional & illegal activities continue to cost Plaintiffs’ business income. (Exhibit B attached). 13. A third example of a lost business relationship can be found in an e-mail dated October 17, 2014 (Exhibit C attached). The director of the | Mother Agency, Vladmir Yudashkin, states that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs’ will force her into illegal activities. The model bases her fears upon the stories on the internet falsely implicating Plaintiffs as being involved with illegal activities with young models. This is HOUSE_OVERSIGHT_011914

another example of a false link between Epstein and Plaintiffs, costing Plaintiffs’ business income. 14. A fourth example of a lost business relationship can be found in a second e-mail dated October 17, 2014 (Exhibit D attached). Manuela Martinez of Mega Partners, a Brazilian modeling agency, states to Plaintiff Brunel that her agency has been unable to work with Plaintiff MC2 for the past five to six years because of the sex trafficking allegations against Plaintiffs . This reference is clearly to the false allegations online regarding sex trafficking that were based in the false link between Epstein and Plaintiffs. 15. A fifth example of a lost business relationship can be found in an e-mail dated on Plaintiff's behalf was an e-mail dated August 27, 2010 from Michelle Stockman of Agence France Presse. (Exhibit E attached). Agence France Presse is a newswire service with a world- wide reach. Stockman wanted to meet with Plaintiff Brunel to arrange a model shoot with MC2. However, due to the adverse publicity surrounding Plaintiffs as a result of Epstein’s illegal activities, Plaintiff Brunel was forced to forego (and lose) this business opportunity because he needed to keep a low-profile at this time. i6. A sixth example of lost business due to Epstein’s intentional and illegal activities can be found in an e-mail dated December 12, 2014. (Exhibit F attached). Michael Sanka, a talent scout who had worked with Plaintiffs for a number of years, informed Plaintiff Brunel that he cannot sign any new models for Plaintiff Brunel’s MC2 agency due to the false sex trafficking allegations online. Sanka goes on to state that Plaintiff Brunel’s MC2 agency will not attract any new models if Plaintiff Brunel does not clear up the false allegations. 17. | A seventh example of lost business due to Epstein’s intentional and illegal activities can be found in an e-mail from Fox Fashion Agency (Exhibit G attached). This e-mail clearly states HOUSE_OVERSIGHT_011915

that Fox has placed models with Plaintiff MC2 in the past with absolutely no problems. However, because of the false internet trafficking links between Plaintiffs and Epstein, Fox states that it cannot place anymore models with Plaintiff MC2 until the allegations are cleared up. 18. Before the false links between Plaintiff and Epstein surfaced, Plaintiff Brunel was earning a great deal of revenue from MC2 Miami. 19. The false links between Plaintiffs and Epstein began to surface online in about 2005- 2006. Then, in 2006, Plaintiffs received a letter of credit from Epstein at 5% interest. Plaintiffs then made an investment totaling one-million dollars with Elite Paris, to start a company. 20. Next, Plaintiff Brunel started the company, “E Management”, to work with Elite Models in Paris, Plaintiff had to close it almost immediately, because Elite didn’t send any models to Plaintiff MC2 for fear of being linked to Epstein. 21. Because the false links between Plaintiffs and Epstein began to gain strength online, Elite Paris severed the agreement due entirely to these false links. Plaintiff Brunel lost his investment of one-million dollars because of this loss of business. 22. Plaintiffs lost potentially ten-million dollars in profits due to this initial one-million dollar loss. 23. Additionally, a former financial controller of MC2, Maritza Vasquez, stated in a 2012 deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under- age model. (Exhibits H! & H2 -Transcript of Deposition of Maritza Vasquez). 24. Maritza Vasquez was fired from her job at Plaintiff MC2 for embezzling company funds, and had criminal charges filed against her (Composite Exhibit I attached). She was also the source of the false information linking Plaintiffs to sex trafficking in the articles written by Conchita Sarnoff of the website Jezebel (Composite Exhibit A, p.2-7). HOUSE_OVERSIGHT_011916

25. The deposition testimony of Maritza Vasquez referred to above clearly demonstrates that Plaintiff Brunel has clean hands and was never involved in sex trafficking. All of Plaintiffs’ damages came solely from Epstein’s conduct. 26. Additionally, Plaintiff Brunel has had significant delays in obtaining his visa to come to the U.S. These delays were also the result of the false link between Plaintiffs and Epstein. Asa result of these delays, Plaintiffs lost a considerable amount of time & money. International travel is a significant component of Plaintiff Brunel’s MC2 modeling business. Plaintiff Brunel has been forced to cancel his latest visa application as a result of the delays. (Exhibit J — Composite — Visa Docs). 27. Asa result of the notoriety and tremendous publicity surrounding Epstein’s criminal charges, and the media linkage of Epstein to Plaintiffs regarding illegal activities, Plaintiffs lost a tremendous amount of business and revenue. 28. Plaintiff Brunel’s agency MC2 has lost millions of dollars in revenue since the media revealed that Plaintiffs and Epstein were associated. In fact, Plaintiff MC2 was worth millions of dollars; now, due to the illegal actions of Epstein, MC2 is almost worthless. 29. Atno time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the Epstein’s illegal activities. 30. Asaresult of Epstein’s illegal activities and his association with Plaintiffs, Plaintiffs continue to lose money and suffer damages to this day. (Exhibit K attached, Jeff Fuller email, } 1-12-14). 31. Plaintiff Brunel will need to spend millions of dollars in order to restore his business to what it was once worth — money that the Plaintiff Brunel does not have. HOUSE_OVERSIGHT_011917

32, Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, their names never having been cleared from the massive and totally negative media coverage involving Epstein and his illegal activities. Plaintiffs have been, and continue to be, irreparably harmed by these false internet-based links to Epstein. (Exhibits R & S attached). 33. Second, Plaintiff Brunel was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunel in a criminal case against Epstein. On the direct advice of Epstein, Plaintiff Brunel went to Europe and Asia for a period of time. This was done for the sole purpose of delaying Plaintiff Brunel’s deposition. 34. Asa direct result of Plaintiff Brunel’s travels, his deposition was delayed twice. When it was finally scheduled for November 2009, Plaintiff Brunel was in fact available (Exhibit L attached). However, a medical emergency in the family of his attorney further delayed this deposition (Exhibit M attached). It was never rescheduled and he was never deposed. 35. This was a blatant example of obstruction of justice in the criminal case. Epstein was solely responsible for telling Plaintiff Brunel to leave the area. Plaintiff Brunel lost a huge opportunity to clear his name, and that of his agency, Plaintiff MC2. 36. Third, as a result of all of the facts stated above, Plaintiff Brunel was under tremendous psychological pressure throughout this period of time. 37. This psychological pressure resulted in Plaintiff Brunel avoiding business contacts as set forth above. This pressure also directly caused Plaintiff Brunel to avoid certain social contacts during this period of time. 38. Plaintiff Brune] became extremely withdrawn and anxious at this time. 39. — Epstein’s conduct was the direct cause of Plaintiff Brunel’s psychological state. The press was reporting extensively on the lurid details of Epstein’s illegal activities with the under- aged girls. HOUSE_OVERSIGHT_011918

40. _ As Stated above, the press reports were erroneously connecting both Plaintiffs to Epstein’s illegal activities. (Composite Exhibit A attached). 41. Epstein’s illegal activities were outrageous and extreme; they involved receiving massages from the under-aged girls while the girls were nude or nearly-nude; penetration of the girls with a finger or object; or full-intercourse. 42. These activities described above caused Plaintiff Brunel severe emotional distress. In fact, Plaintiff Brunel has recently undergone psychotherapy with a local psychologist, Dr. Royce N. Jalazo, as a result of Epstein’s actions and the negative results on his business. (Exhibits N & O attached). 43. Plaintiff Brunel is emotionally destroyed as a result of Epstein’s actions and the resultant effects on his business. He has been on medications to deal with the effects of this. (Composite Exhibit P — Medical History). 44. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counsel to represent him in this matter, and are obligated to pay counsel a reasonable fee for his services. FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A YLORG 45. Defendant Tyler McDonald (“McDonald”) is the owner/operator of Yi.Org and also does business as Yi.Org — Defendant Tyler McDonald d/b/a Yi.org (“McDonald d/b/a Yi.Org”). Defendant McDonald resides in the state of Washington. Yi.Org is a website hosting service based in Vancouver, British Columbia, Canada. 46. In about 2009, Yi.org, by and through the actions of its owner, McDonald, began hosting websites that contained hyperlinks that contained blatantly false and extremely disparaging information about Plaintiffs. (Exhibit Q attached - hyperlink screenshot). HOUSE_OVERSIGHT_011919

47. These links clearly and falsely associated Plaintiffs with illicit escort services in the state of Florida; information which Defendants McDonald and McDonald d/b/a Yi.Org knew, or should have known, was false. 48. These links have damaged Plaintiff Brunel’s reputation as an owner of a well-established modeling agency with offices in New York and Miami, Plaintiff MC2. 49. These links have also damaged the reputation of both Plaintiffs. 50. The combined damage to the reputation to both Plaintiffs has resulted in a significant loss of revenue to Plaintiff MC2, and accordingly, to Plaintiff Brunel. 51. Plaintiff MC2°s revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org. 52. Both Defendants McDonald d/b/a Yi.Org and McDonald assisted in the dissemination of the false and negative information that damaged Plaintiffs’ reputation and directly caused damages to Plaintiffs. 53. Plaintiff Brunel continues to own and operate Plaintiff MC2 to this day, both names still harmed by the false and negative association with escort services in Florida. 54. Accordingly, Plaintiffs have been severely damaged by information on websites hosted by Yt.Org, which is maintained, owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald. 55. The information disseminated by the websites hosted by Defendants McDonald d/b/a Yi.Org and McDonald was false and defamatory to the extreme regarding Plaintiffs alleged involvement with escort services in the state of Florida. 56. Defendants McDonald d/b/a Yi.Org and McDonald have made no attempt to clear the names of Plaintiffs with regard to the false and defamatory information disseminated by the HOUSE_OVERSIGHT_011920

websites they hosted. 57. Plaintiffs continue to do business to this day, their names never having been cleared from the negative information disseminated by Defendants McDonald d/b/a Y1.Org and McDonald. 58. Plaintiffs have been damaged by the conduct of Defendants McDonald d/b/a Yi.Org and McDonald, and have accordingly retained undersigned counsel to represent him in this matter, and are obligated to pay counsel a reasonable fee for his services. COUNT I - EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANT JEFFREY EPSTEIN 54, The allegations contained in paragraphs | through 44 above are re-alleged and incorporated herein by reference. 60. Plaintiffs have lost a significant amount of business revenue because of the actions of Defendant Epstein set forth above. 61. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of Defendant Epstein. 62. Accordingly, Plaintiffs seeks to become whole by the payment of damages by Defendant Epstein to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT II —- OBSTRUCTION OF JUSTICE — EQUITY - AS TO DEFENDANT JEFFREY EPSTEIN 63. The allegations contained in paragraphs | through 44 above are re-alleged and incorporated herein by reference. 10 HOUSE_OVERSIGHT_011921

64. —— Plaintiff was forced to commit illegal acts by traveling away from the sight of the deposition and during the time period of the deposition. 65. Defendant Epstein attempted to subvert justice and this attempt contributed to the destruction of Plaintiffs business, Plaintiff MC2. Plaintiff Brunel lost substantial time away from his business and incurred expenses in following Epstein’s commands. 66. Plaintiffs were substantially damaged as a direct result of Epstein’s actions. WHEREFORE, PLAINTIFFS request judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT Il —- INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 67. The allegations contained in paragraphs 1 through 44 above are re-alleged and incorporated herein by reference. 68. Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by engaging in illegal conduct with under-aged girls, which was falsely linked to Plaintiffs. 69. =‘ This illegal conduct was extreme and outrageous by any standard. 70. This extreme and outrageous conduct was the direct cause of extreme emotional distress in Plaintiff Brunel. WHEREFORE, PLAINTIFF BRUNEL requests judgment against DEFENDANT as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate HOUSE_OVERSIGHT_011922

COUNT IV —- EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG 71. The allegations contained in paragraphs | through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 72. Plaintiff, through his agency MC2, has lost a significant amount of business revenue because of the actions of Defendants McDonald d/b/a Yi.Org and McDonald set forth above. 73. Plaintiffs have no adequate legal remedy to make him whole as a result of the damages suffered in the form of lost business revenue due to the actions of both Defendants. 74. Accordingly, Plaintiffs seek to become whole by the payment of damages by both Defendants to compensate him for his losses. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; tria! by jury and B. Grant other such relief as is appropriate. COUNT V — DEFAMATION AGAINST PLAINTIFFS — AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YLORG 75. The allegations contained in paragraphs | through 3 & 45 through 58 above are re- alleged and incorporated herein by reference. 76. Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published, false statements about Plaintiffs using their domain hosting service. 77. Defendants McDonald d/b/a Yi.Org and McDonald knew, or should have known, that the statements about Plaintiffs were false. 78. These published statements were read by the internet users who viewed the false statements. 79. Plaintiffs” business reputations were severely damaged as a result. HOUSE_OVERSIGHT_011923

WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. COUNT V1— EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A/ YILORG 80. The allegations contained in paragraphs 1 through 3 & 45 through 48 above are re- alleged and incorporated herein by reference. 81. Plaintiffs have also suffered a significant loss of their business reputations as a direct result of the actions of Defendants McDonald d/b/a Yi.Org and McDonald. 82. Plaintiffs have no adequate legal remedy to make them whole as a result of the damages suffered in the form of lost business reputations due to the actions of both Defendants. 83. Accordingly. Plaintiffs seeks to restore their business reputations by the payment of damages by both Defendants to compensate them for their loss of reputations. WHEREFORE, PLAINTIFFS request judgment against DEFENDANTS as follows: A. Damages in excess of fifteen-thousand dollars; trial by jury and B. Grant other such relief as is appropriate. /s! Joe Titone Joe Titone Attorney FL BAR #: 203882 621 S.E. 5" Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) [email protected] HOUSE_OVERSIGHT_011924

VERIFICATION STATE OF FLORIDA } ) COUNTY OF titeey fad?) JEAN-LUC BRUNEL, being duly swom according to law, upon his oath, deposes and says: ] have read the foregoing complaint and all the allegations contained thergin. All such allegations are true based upon my personal knowledge, information and belief. i i BRU ae a NOTARY PUBLIC HOUSE_OVERSIGHT_011925

COMPOSITE EXHIBIT A HOUSE_OVERSIGHT_011926

http://www.thedailybeast.com/articles/2010/07/29/jeffrey-epstein-feds-probe-possible-child- trafficking-charge.html] Epstein Faces Sex-Traffic Probe The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last week. But it appears his problems may not be over. Now The Daily Beast has learned that: * Federal investigators continue to investigate Epstein’s activities, to see whether there is evidence of child trafficking—a far more serious charge than the two in his non- prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. ° The FBI is also investigating Epstein’s friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein’s private jets. Because Epstein’s predatory habits stretch back many years and involved dozens of young- looking girls, there may well be more evidence to uncover. Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, fund the civil suits of named victims, and register as a sex offender, The victims who accepted cash settlements in these civil suits agreed not to testify against him or speak publicly about the case. However, new evidence developed by the Department of Justice on other offenses not covered by the agreement, including allegations by additional victims who come forward, could lead to new charges. There is no statute of limitations in the federal sex- trafficking law, which was also enacted by the state of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of young-looking girls, there may well be more evidence to uncover. (Several young women who claim to be Epstein victims have recently contacted a Ft. Lauderdale lawyer, but to date no new civil complaints have been filed.) * Conchita Sarnoff: The Billionaire Pedphile's Sex Den * Billionaire Pedophile Goes Free These new developments come one week after the publication of two articles in The Daily Beast about Epstein’s pattern of sexual contact with underage girls, which Palm Beach police began investigating in 2005 and the U.S. Attomey’s office then settled in a 2007 plea deal. The first 16 HOUSE_OVERSIGHT_011927

article quoted a deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein, a billionaire with many powerful friends, had received special treatment in both his plea deal and the terms of his incarceration. Although federal investigators at one point produced a draft 53-page indictment against Epstein, he was eventually allowed to plead guilty to only two relatively minor state charges and receive a short term of incarceration: 13 months in the county jail, during which he went to the office every day, and one year of community control, during which he traveled frequently to New York and his private island in the Virgin Islands. The Daily Beast has now discovered another instance in which Epstein apparently received special consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This is because child molesters tend to be repeat offenders with high rates of recidivism. According to a source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been disconnected with no forwarding information. The Daily Beast’s second article provided details about Epstein’s systematic abuse of underage girls at his Palm Beach mansion, where members of his staff allegedly recruited and paid a parade of teenagers, most of them 16 or younger, to perform daily massages that devolved into masturbation, groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between Epstein and Jean Luc Brunel, a frequent visitor to whom 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 policy to confirm or deny the existence of an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein’s complete fulfillment of all the terms of his non-prosecution agreement with the federal government." Conchita Sarnoff has developed multimedia communication programs for Fortune 500 companies and has produced three current-events debate TV programs, The Americas Forum, From Beirut to Kabul, and a segment for The Oppenheimer Report . She is writing a book about child trafficking in America HOUSE_OVERSIGHT_011928

http:/Avww.thedailybeast.com/articles/2010/07/22/jeffrey-epstein-pedophile-billionaire-and- his-sex-den. html The Billionaire Pedophile's Sex Den Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-daily massages, pornographic artwork, and hush money—that’s only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive exposé. Hedge fund mogul and sex offender Jeffrey Epstein, who went free this week, lived in a depraved world of thrice-daily massages, pornographic artwork, and hush money—that’s only now being revealed. Conchita Sarnoff reports on the sordid details in part two of her exclusive exposé. Also: « Nude images of young girls were scattered around the house and the bathroom soap was shaped like sex organs * Staff trolled for fresh recruits to make sure Epstein had two or three massage appointments each day * The house manager has been sentenced to a longer prison term than Epstein—for trying to sell notes regarding massage appointments * Epstein gave $1 million to his friend Jean Luc Brunel when he was starting the modeling agency MC2 * According to a former bookkeeper, young girls were brought to the U.S. by MC2— often from Eastern Europe—then traveled on Epstein’s private jets Jetfrey Epstein’s loyal friends say that his prosecution was unduly harsh, rather than outrageously lenient. They insist that his sexual habits, although obsessive and unusual, were mostly legal and essentially harmless. As the police records attest, the girls brought to El Brillo Way were routinely told they could “say no” at any time during a massage as Epstein escalated contact in a step-by-step assault that was remarkably similar in every victim’s statement: First she would be asked to remove her shirt, then her pants. He would attempt to fondle her buttocks and breasts as he masturbated, then bring out a large vibrator. There was sometimes digital penetration, and the more willing girls were lured into full-blown sexual relations with both Epstein and Nadia Marcinkova, who was referred to in press accounts and police reports as Epstein’s live-in “sex slave.” A former bookkeeper in the Miami office, who also arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein’s private jets. HOUSE_OVERSIGHT_011929

It’s true that some underage girls may have lied about their age, and some came to the house voluntarily several times—although, according to Florida statutes, none of that has any bearing on the criminality of the contact, particularly if the girl was 16 or younger. But what is particularly disturbing about this case—judging by arrangements at the Palm Beach house—is that Epstein, a billionaire hedge-fund manager, organized his life around this sexual compulsion in an open and methodical way that suggests he felt he was beyond the law. * Conchita Sarnoff: Epstein Faces Sex Traffic Probe * Billionaire Pedophile Goes Free According to police who executed a search warrant, the house was decorated with large, framed photos of nude young girls, and similar images were found stashed in an armoire and on the computers seized at the house (although police found only bare cables where other computers had been). Some bathrooms were stocked with soap in the shape of sex organs, and various sex toys, such as a “twin torpedo” vibrator and creams and lubricants available at erotic specialty shops, were stowed near the massage tables set up in several rooms upstairs. Epstein also enlisted his staff in the predatory activity, and four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged. According to police reports and swom statements in the civil suits, all four women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily “massages” was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein’s live-in partner, also recruited young girls. Since his 13-month sentence for soliciting prostitution with a minor, Epstein has settled more than a dozen lawsuits brought by underage girls. Seven victims reached a last-minute deal last week, days before a scheduled trial; each received well over $1 million—an amount that will hardly dent Epstein's $2 billion net worth. The victims told police they waited in the kitchen to be called upstairs for a massage, and the house chef often gave them a bite to eat. House manager Alfredo Rodriguez said in his sworn statement that a maid named Lupita, who was a devout Catholic, wept when she complained to him about cleaning up after the massage sessions, picking up soiled towels and putting away the sex toys. And she was upset that a photo of Epstein with the pope hung next to one of him with a young girl. Ironically, Rodriguez, who ran the house on El Brillo Way in 2004 and 2005, ended up being sentenced to more jail time than his boss as a result of the complex investigation into Epstein’s activities. He was fired, he says, for inadvertently drawing police attention to one of the girls when she arrived at the house unannounced to collect money. He saw an unfamiliar “beater” in the driveway one evening and called 911. When he left Epstein’s employ, Rodriguez took away some notes and emails about massage appointments as “protection” against his own prosecution, and failed to produce them during the Palm Beach Police Department’s initial investigation. Unable to get work as a house manager elsewhere in South Florida, he says, Rodriguez later tried to sell this “golden nugget”—his term—for $50,000, to be used in the victims’ civil suits. 19 HOUSE_OVERSIGHT_011930

Unfortunately, he made the offer to an undercover cop, and was subsequently charged with “obstruction of official proceedings” for withholding information that could have advanced the criminal investigation of Epstein—which by that point had been settled in a plea deal. Rodriguez was sentenced to 18 months in federal prison (Epstein was allowed to serve 13 months in the Palm Beach county jail), and now awaits an additional sentence on Aug. 24 in federal court in Miami for transporting firearms, another deal he says he made to pay the bills after he lost his job. In a deposition given for the civil suits, Rodriguez testified that he was instructed to always have $2,000 in cash on hand, so that he could pay both the girls who gave massages and recruiters such as Haley Robson who brought them to the house. He also testified that Epstein made large contributions to the Palm Beach Police Department, and in return was given PBPD baseball hats to put on the dashboard of his various cars to avoid being stopped or ticketed by local police. Retired Police Chief Michael Reiter, in his own deposition, acknowledged that, in addition to earlier donations to the police department (which are fairly common in well-heeled Palm Beach), Epstein had recently given the department $100,000 for some sophisticated equipment. The police were still researching the purchase when Epstein came under suspicion, and Reiter ordered the money returned. (Guy Frostin, one of Epstein’s local attorneys, told police that Epstein also gave $100,000 to the Florida Ballet for massages, because he was ‘very passionate” about massages being “therapeutically and spiritually” beneficial. Yet victims told police they had no massage training.) Perhaps most disturbing, in terms of possible sex trafficking, was Epstein’s relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and Marcinkova “deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money.” (Which would amount to trafficking.) Brunel is a 50-plus French playboy who was formerly part owner of Karin, a Paris-based modeling agency. He lives in New York and South Beach, Florida, and owns 85 percent of MC2., which has offices in New York, Miami, and Tel Aviv. (The remaining 15 percent is owned by his partner, Jeff Fuller.) Brunel has been observed as a house guest at Epstein’s Palm Beach home and may well have had contact with him also in New York, where Epstein owns a lavish home, and in Paris, where Epstein keeps an apartment on elegant Ave. Foch. CBS reporter Craig Pyes, who investigated Brunel for a 60 Minutes broadcast many years ago, is quoted in Michael Gross” book about the modeling industry, Model: The Ugh: Business o Beautiful Women. Pyes told the author that Brunel “ranks among the sleaziest people in the fashion industry. We’re talking about a conveyor belt, not a casting couch. Hundreds of girls were not only harassed but molested.” Now The Daily Beast has learned that Epstein had made a $1 million wire transfer to Brunel’s offshore bank account in September 2004, just as he was setting up MC2. Whether this was a gift or a loan or a backdoor investment in the new venture is unknown. A French citizen who managed to avoid giving evidence in the Epstein investigation, Brunel declined to comment on any of this, as does Fuller. Asked in April of Brunel's activities, 20 HOUSE_OVERSIGHT_011931

Epstein said “I’m 100 percent convinced that he doesn’t traffic children.” (Brunel has never been charged.) An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many were from Eastern Europe and spoke little English. A former bookkeeper in the agency's Miami office, who also arranged visas for girls traveling to the U.S., confirmed that MC2 girls became frequent guests on Epstein’s private jets. Pilot logs obtained in the civil suits show that some of the named plaintiffs were on the flight manifests. Other times, the pilot would just list the other passengers plus "femmale.” Editor’s Note: An earlier version of this article misidentified the subject of Craig Pyes’ investigation and the title of Michael Gross’ book. The Daily Beast has corrected the subject and title and regrets the error. Read Conchita Sarnoff's original report on Epstein. Conchita Sarnoff has developed multimedia communication programs for Fortune 500 companies and has produced three current events debate television programs, The Americas Forum, from Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Huffington Post. She is writing a book about child trafficking in America. 2] HOUSE_OVERSIGHT_011932

http://fashioncopious.typepad.com/fashioncopious/2010/08/mc2-modeling-agency-involved-in-sex- trafficking.html MC2 Modeling Agency Involved In Sex Trafficking August 11,2010 On August 4th Jezebel ran the following story: The Sex-Trafficking Model Scout. Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova ‘deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money. The previous paragraph in the story read: and making [speaking of Jeffrey Epstein] frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave": paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. oe HOUSE_OVERSIGHT_011933

http://bettyfokker.wordpress.com/20 1 0/08/20/hes-helping-others-get-away-with-child-sex- trafficking/ He’s helping others get away with child-sex trafficking Posted on August 20. 2010 by Betty Fokker Let’s discuss that billionaire douche-face child-rapist, Jeffrey Epstein for a moment shall we? He’s someone who likes to have sex with venerable underage girls, including 12 year old girls who are trafficked into the US under the guise that they will become models. His partner in crime was Jean Luc Brunel, owner and ‘talent scout’ of the MC2 “modeling agency’. Epstein coincidently invested a million bucks in the MC2 kiddie-perating modeling agency and let Brunel use his privet jet. The FBI thinks Epstein has assaulted/molested about 40 or so young girls. So he’s going to prison for the rest of his life right? Wrong. When faced with the best defense lawyers money could buy, the prosecutors wimped out and made a plea bargain so light it boggles the mind. This kid-raping bastard only had to please guilty to two MINOR charges and gets a private cell, a cell he gets to leave on a “work release program” by the way. Now, I am not blaming his defense attorneys. They were doing their job and, under our constitution, a festering anus like Epstein has the right to the best attorneys he can afford. ] am livid with the prosecuting attorneys. It was their job to do everything in their power to bring this vomit-inducing shit-sack to justice. Instead, they decided to gutlessly pander to his wealth, privilege, and powerful defense team. They rolled over and did everything but send in another kid to give this fucker a hand-job. So this vermin got away with raping 12 year old girls because the prosecuting attorneys couldn’t find a single testicle/ovary to share among them. And do you know what their chicken-shit kowtowing to Epstein has wrought? It’s opened the door for other child-sex traffickers to get fighter sentences for their crimes too. Why should they have to pay when he didn’t? After all, it was just girls they were trafficking for sex with disgusting older males (1 refuse to call something like Epstein a “man”; it insults men) ... they weren't harming anything of any value in our culture! I'm a feminist because I think girls & women have value. What a crying, fucking shame there wasn't one feminist in the prosecutors office to go after this monster and punish him. What a pity other hell-spawn might get away with trafficking girls for sex more easily because of the shit- for-brains attorneys who let Epstein get away with his crimes. My eyeballs are melting with rage. Never mind. They aren’t melting. It’s just tears of helpless and despairing rage against an unjust legal system and the cultural devaluation of women and girls. 23 HOUSE_OVERSIGHT_011934

http://gawker.com/5600294/recently-freed-sex-offender-jeffrev-epstein-may-face-child- trafficking-charges Recently-Freed Sex Offender Jeffrey Epstein May Face Child Traffickin Charges Ce eae al ht, Ct iam Slirwedes PRTC USTEN ‘pee 7 eg Lr es aT see See eet af ees == Expand Ads by Google Jeffrey Epstein, the billionaire Bill Clinton pal who just left jail after completing a sentence for soliciting sex with a minor, may be headed back soon: The Daily Beast reports that the Justice Department is investigating him for child trafficking. Epstein, famous for being rich, being friends with Bill Clinton, having an egg-shaped penis, and being a vindictive pervert, can't be prosecuted again for the charges he copped to in his plea deal. But according to The Daily Beast's Conchita Sarnotf, new charges might be coming: As we learned in Vanity Fair yesterday, Bill Clinton has spent his post-presidential life...Read more Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking-a far more serious charge than the two in his non-prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to plead guilty to lower-level state crimes, Trafficking can carry a 20-year sentence. Since there's no statute of limitations for sex-trafficking, and Epstein's predatory adventures apparently date back more than a few years, it's likely there's more women who could come forward. (Apparently some have contacted a lawyer, but nothing's been filed yet.) It's not just Epstein, either—his buddy Jean Luc Brunel, head of the MC2 modeling agency, is also being investigated, and some of the models he represented (many from overseas) may have been enlisted as companions on Epstein's private jet. 24 HOUSE_OVERSIGHT_011935

http://www. huffingtonpost.com/2014/06/03jeftrey-epstein_n_5439407.html MIAMI (AP) — Nearly a decade ago, a wealthy financial guru came under FBI investigation, suspected of sexually abusing dozens of underage girls at his Palm Beach mansion. Then, abruptly. the investigation was dropped and Jeffrey Epstein pleaded guilty to a single state charge of soliciting prostitution. He served just over a year in jail. Now, two women who say they were among his victims have won a precedent-setting appeals court ruling entitling them to see all the documents from the plea bargain discussions between Epstein's high-powered lawyers and federal prosecutors. Their goal: use those files to undo the agreement, reopen the investigation and subject Epstein to more charges. The women's lawyers contend Epstein got special treatment because of his wealth and connections. His attorneys deny that. Epstein, 61. made hundreds of millions of dollars managing funds for rich clients, Shortly after his 2008 guilty plea. it came to light that his lawyers had secretly reached a non-prosecution agreement months earlier with the U.S. Justice Department that spared him a potentially heavier punishment. “Our complaint alleges that. prodded by Epstein. the federal prosecutors deliberately concealed the sweetheart plea deal they made with him to avoid public criticism.” said Paul Cassell. a University of Utah law professor who is representing the two women. The U.S. attorney's office in Miami would not comment. But the U.S. attorney at the time. R. Alexander Acosta, said in a 2011 letter defending his office that more evidence came to light after Epstein made his deal. "Many victims have spoken out. filing detailed statements in civil cases seeking damages. Physical evidence has been discovered," Acosta wrote. "Had these additional statements and evidence been known, the outcome may have been different.” Epstein has settled lawsuits for undisclosed amounts with many of the women who say they were underage when they were paid for sex. The case represents the first time a federal appeals court has ruled that the Crime Victims’ Rights Act of 2004 guarantees victims the right to be informed about the details of how a plea bargain was reached, according to legal experts and lawyers involved in the case. The law marked the culmination of efforts begun in the 1960s to give crime victims more of a say, 25 HOUSE_OVERSIGHT_011936

“! hope that the case will ultimately set an important precedent that federal prosecutors can't keep victims in the dark about the plea deals that they reach." Cassell said. Epstein served 13 months of an 18-month sentence on the prostitution charge. sold his Palm Beach home in 2011 and now divides his time between a New York City home. a Caribbean island and an apartment in Paris, according to court documents. He also has a large New Mexico ranch, He donates huge sums each year, particularly toward projects involving new medical treatments and artificial intelligence, His foundation established a Harvard University program that uses mathematics to study evolutionary biology. viruses and disease. According to lawsuits filed by some of his accusers. Epstein relied on assistants to recruit underage girls to give him massages and perform sex acts. They were usually paid about $200. Some girls were notified about the investigation beginning in 2006, But they weren't told about the negotiations with federal prosecutors for at least nine months, despite a requirement in the Crime Victims' Rights Act that they be kept informed. The two women — who were 13 and 14 when the alleged assaults occurred — sued for the files and won. "Although plea negotiations are vital to the functioning of the criminal justice system. a prosecutor and target of a criminal prosecution do not enjoy a relationship of confidence and trust when they negotiate.” the appeals court said. Federal prosecutors have begun turning over the documents, Epstein's atlomey. Roy Black, the celebrity lawyer who is also representing Justin Bieber in his DU] and resisting-arrest case in Miami Beach, declined to comment but has asked that the documents be kept from public view, and so far they have been. Ina May 23 court filing, Black said that there was no conspiracy between prosecutors and Epstein’s team to violate the victims’ rights law and that the non-prosecution agreement contained many provisions Epstein strongly opposed. such as registering as a sex offender and agreeing not to contest certain lawsuits. "This was no sweetheart deal by any stretch of the imagination." Black said in court papers. Even if a judge invalidates the plea deal, it will still be up to federal prosecutors to decide what to do. "The court can't force the prosecutors to bring charges." said Matt Alexrod, a former federal prosecutor now in private practice in Washington. 26 HOUSE_OVERSIGHT_011937

http:/Awww.huffingtonpost.com/conchita-s-sarnoff/child-trafficking b_1269748.html Conchita Sarnoff Communications expert Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published "The Sex Trafficking Model Scout” warning about the dangers of deregulated modeling agencies in the U.S, Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as “models.” Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and "no criminal charges have been filed by any of his accusers" -- although many have tried to serve him including lawyers representing Epstein's victims, Brunel continues to hide behind his French citizenship to prevent depositions. "Trawling for 5'11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations." Given his citizenship he also successfully avoided deposition in Epstein's sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, "he did not respond to our interview request." According to Jezebel: 27 HOUSE_OVERSIGHT_011938

we spoke to a number of peaple who worked with his agency and while MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either... Brunel isn't involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a ‘scouting tsunami’ and MC2 is fairly well known for the strength of its international scouting. Model, Michae! Gross's 1995 book, describes Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. “Jean-Luc is considered a danger," says Jér6me Bonnouvrier. "Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always been on the edge of the system." John Casablancas, founder of Elite modeling agency said: [ really despise Jean-Luc as a human being for the way he's cheapened the business. There is no Justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Street Journal magazine. In that story "A Model Trade Union," Ford describes herself as a "roving ambassador" to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. "In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women's leadership group that was studying the issue of trafficking. "I said, 'I can't come talk about it, because I don't know anything about it!"" Ford recalls. "But | went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford "the target age is 14 to 24, and so it's similar to modeling." I knew how to reach that market" she said, "It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls." http://jezebel.com/3603638/meet-the-modeling-agent-who-trafficked-underage-girls-for-sex The Sex-Trafficking Model Scout 28 HOUSE_OVERSIGHT_011939

Expand Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a prominent modeling agent and scout. Here's what we know about Jean Luc Brunel. Jeffrey Epstein, you will no doubt recall, is the man who thought ferrying Bill Clinton on his private jet, lawyering up with superstar Alan Dershowitz, and making frequent $100,000 donations to the Palm Beach Police Department would insulate him from prosecution for his various depravities. Say you're not as famous or celebrated as Roman Polanski and you want to sexually assault...Read more Which included, for the record: buying a 14-year-old Yugloslavian named Natalia Marcinkova from her parents in order to keep Marcinkova as his "sex slave"; paying a retinue of women to trawl Palm Beach for teenagers economically desperate enough to agree to give Epstein "massages" that often led to sexual contact; receiving two 12-year-old French girls as a "birthday present"; and befriending Michael Wolff. But as Conchita Sarnoff wrote at The Daily Beast: Perhaps most disturbing, in terms of possible sex trafficking, was Epstein's relationship with Jean Luc Brunel, owner of the MC2 modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova ‘deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engage in sexual play for money. The FBI investigated Epstein, and identified around 40 underaged victims. Sarnoff reports that the FBI is also investigating MC2 and Brunel for possibly engaging in child sex trafficking. Since pleading guilty to reduced charges of soliciting sex with a minor and serving 13 months of 20 HOUSE_OVERSIGHT_011940

part-time jail, Epstein has become the focus of numerous civil lawsuits from his victims. He has so far settled a dozen. These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper, a number of the girls worked for MC2, the modeling agency owned by Jean Luc Brunel, a longtime acquaintance and frequent guest of Epstein's. Brunel, along with numerous young models, was a frequent passenger on Epstein's private jet, according to flight manifests. The agency owner also allegedly received $1 million from Epstein in 2005, when he founded MC2 with his partner, Jeffrey Fuller; although Fuller and Brunel denied any such payment from the billionaire pervert in 2007, when rumors started swirling, Samoff got confirmation from a former bookkeeper at the agency. Whether the money was a secret investment in MC2, or a payment for Brunel's services as a procurer, is unknown. Brunel also visited Epstein in jail. So who is Jean Luc Brunel? Although he did not respond to our interview request, we spoke to a number of people who have worked with his agency. While MC2 isn't considered a major industry player, it isn't exactly bottom-shelf, either: MC2 in New York most recently launched the career of Latvian editorial star Ginta Lapina (Brunel "discovered" Lapina via an MC2 scouting competition for young teens) and currently represents Vogue China covergirl Liu Dan. Worldwide, MC2 represents such stars as Sessilee Lopez in Miami, and top models Candace Swanepoel, Marina Lynchuk, Natalia Chabanenko, and Elisa Sednaoui in Tel Aviv. Brunel isn't involved with the business on a day-to-day basis, although he owns an 85% stake in MC2. Instead, "Right now he does scouting for [the] agency and takes care of the international relations with other agencies,” reports one source. Scouts scour the world for un-agented teenaged girls who could make it as models; they work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight — even relative to the almost totally unregulated modeling industry itself. "He travels a lot," says another person who has worked with Brunel. (The company blog refers to Brunel as a "scouting tsunami," and MC2 is fairly well-known for the strength of its international scouting.) Models we spoke to report mostly positive experiences with Brunel — one praised his sense of humor and said he is “lovely to all of his models," and another described him as highly intelligent and cultured, adding, "he knows a lot about the opera and he paints" — although it should be noted that none of the models whom we spoke to had been told of either his connections with Epstein, or his past. And what a past it is. These accounts from Michael Gross' 1995 book Model describe Brunel's activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karins, now known as Karin Paris: “Jean-Luc is considered a danger," says Jér6me Bonnouvrier. "Owning Karins was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He's always 30 HOUSE_OVERSIGHT_011941

been on the edge of the system. John Casablancas gets with girls the healthy way. Girls would be with him if he was the butcher. They're with Jean-Luc because he's the boss. Jean-Luc likes drugs and silent rape. It excites him." "I really despise Jean-Luc as a human being for the way he's cheapened the business," says John Casablancas. "There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano...They were very well-known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps." It should be noted that aside from being a professional rival, Casablancas, the founder of the agency Elite, was eventually drubbed out of the industry for his own modelizing. How pervy do you have to be for John Casablancas to call you a perv? Pervy enough to drug and rape numerous teenagers, according to 60 Minutes and Diane Sawyer, who investigated Brunel in 1988. The program interviewed nearly two dozen models who said they had been sexually assaulted by Brunel and/or by his fellow agent, Claude Haddad. Even at that time, Brunel had a reputation as a man one could go to to procure a "date" with a young model. CBS spoke to five models who said that Brunel and/or his friends had drugged and raped them. Said producer Craig Pyes, "Hundreds of girls were not only harassed, but molested." When Gross interviewed Brunel, this is what he had to say for himself: “You get laid tonight with a model, is that a crime? I don't understand why people go into your personal life, what you do yourself, and to yourself, and they don't look at things that are really important.” Since then, Brunel has been involved with a succession of agencies in New York and Paris. Although the 60 Minutes scandal eventually led Eileen Ford to stop working with him, he continued his involvement with Karins. In 1988, when powerhouse agency Next opened its doors, Brunel took an ownership stake. He also "discovered" Christy Turlington when she was 14. MC2 is only his latest venture. Because no criminal charges were ever filed by any of his accusers, and because the industry has a short memory — most models working today weren't even born when Sawyer and Pyes started looking into Brunel's activities — Brunel has been free to continue as he pleases. A French citizen, he even avoided testifying in his friend Epstein's trial. And so Brunel is still criss-crossing the globe, trawling for 5'10" 13-year-olds from Eastern Europe and (the whiter parts of) South America. And apparently taking the occasional ride with them on Epstein’s private jet. Is there any better argument for the regulation of the modeling industry? http://nypost.com/201 1/1 1/18/jeffrey-epsteins-level-3-sex-offender-status-upheld-by-ny-appeals- court/ 31 HOUSE_OVERSIGHT_011942

Jeffrey Epstein’s Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 | 5:00am Multimillionaire perv Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New York does. A state appeals court yesterday upheld the financier’s status as a Level 3 sex offender — meaning he’s considered “a threat to public safety” and a “high risk” to offend again. Epstein, 58, did 13 months in a Florida jai! for soliciting a minor to perform a sex act on him during a “massage.” Although he was never indicted or convicted for hiring any other underage girls, the state Appellate Division found there was “clear and convincing evidence” he had indeed done so, making the Level 3 designation appropriate. a2 HOUSE_OVERSIGHT_011943

http://pagesix.com/2007/10/06/model-shop-denies-epstein-tie/ MODEL SHOP DENIES EPSTEIN TIE By PageSix.com Staff - October 6, 2007 | 9:00am THE owners of MC2 models are denying industry speculation that massage maven Jeffrey Epstein is a secret financial backer of the agency being run by scandal-scarred Jean-Luc Brunel, who was once accused of taking advantage of underage models. Epstein, who this week agreed to plead guilty to soliciting underage prostitutes at his Florida mansion in a deal that will send him to prison for about 18 months, reportedly gave “millions” to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. “E equals MC squared . . . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out,” said a model industry insider. “He’s a desperate old man that fantasizes and takes advantage of young girls.” The trouble doesn’t stop there. Karins Models founder Brunel, who’s currently a partner in MC2, denied allegations in a 1997 “60 Minutes” segment that he took advantage of young models who were high on drugs. Brunel also reportedly left his Trump Tower digs in 1999 after complaints of night carousing, which he also denied. Disgraced former Elite models exec Gerald Marie is also involved with MC2, says our source. Marie was accused of having sex with underage models in a 1999 BBC documentary where he was filmed saying he hoped to seduce contestants in a modeling contest in which the average age of participants was 15. He also dated Linda Evangelista when she was a teen. ““He’s also involved in the agency,” said the source. “Gerald and Jean-Luc like the same things. They hang out because they have young girls in common, like two guys who enjoy the same wine,” MC2 president Jeffrey Fuller confirmed Brunel was a partner in the company, but denied any working relationship with either Epstein or Marie. “We have no relationship business-wise with Gerald Marie. Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and I are the only two partners and owners of MC2 Model Management,” Fuller said. Epstein’s rep said he was not involved in the agency. “He has no business relationship with them,” said Howard Rubenstein. 33 HOUSE_OVERSIGHT_011944

http://www. palmbeachdailynews.com/news/news/lawsuit-documents-link-jeffrey-epstein- to-modeling/nMGzH/ Lawsuit documents link Jeffrey Epstein to modeling agency owner Jean Luc Brunel By Michele Dargan Daily News Staff Writer New court filings in a civil case filed by billionaire sex offender Jeffrey Epstein link Epstein and Jean Luc Brunel, owner of modeling agency MC2. The documents say MC2 employees told attorney Brad Edwards that Epstein’s condos at 301 E. 66th St. in New York City were used to house young models. Edwards, who has sued Epstein on behalf of several women claiming to be victims of sex abuse by Epstein, was told MC2 brought underage girls in from all over the world, promising them modeling contracts, “Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent,” the documents say. Through the investigation of his lawsuits against Epstein, Edwards learned Brunel “runs the modeling agency MC2, a company for which Epstein provides financial support,” the documents say. They also allege Epstein tried to thwart Edwards from taking depositions of Brunel, Epstein’s companion Guislaine Maxwell, and other high-profile names such as President Bill Clinton. Details are listed in more than 62 pages filed by attorney Jack Scarola on behalf of Edwards in the lawsuit Epstein filed against Edwards. Edwards represents four of Epstein’s minor victims, three of whom have settled their cases with Epstein under a confidential agreement. Epstein attorneys Christopher Knight and Joseph Ackerman declined to comment Friday on the court filings. Edwards deposed Brunel, but his attorney delayed it and then said he was back in France with no plans to return. But according to the court papers, Brunel was staying with Epstein in Palm Beach during that period. 34 HOUSE_OVERSIGHT_011945

The court filings describe Brunel as one of Epstein’s closest pals. Regarding Maxwell, the documents refer to sworn testimony by Epstein’s former house manager, Alfredo Rodriguez, explaining how Maxwell took photos of girls without the girls” knowledge, “kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims.” According to the documents: Maxwell allegedly lied about her mother being ill and having to fly back to England one day before a scheduled deposition in Edwards’ case against Epstein. Despite that assertion, Maxwell was captured in a photo for OK magazine, attending the wedding of Chelsea Clinton two days later. Epstein has settled more than two dozen lawsuits and claims against him by young women who say they were lured to his E] Brillo Way mansion as teens to give him sexually charged massages and/or sex in exchange for money. The terms of all settlements are confidential. Rodriguez took a journal from Epstein’s computer that listed the names of his underage victims from around the country and the world. Calling it the “Holy Grail,” Rodriguez tried to sell the journal for $50,000 to victims’ attorneys. He pleaded guilty to obstruction of justice and is serving |8 months in federal prison, Epstein, 57, served 13 months of an 18-month state sentence. He ended his one-year probation in July on state charges of soliciting prostitution and soliciting a minor for prostitution. According to flight logs from Epstein’s private planes, Clinton flew several times on Epstein’s planes, many times with Maxwell, Palm Beach resident Sarah Kellen and Adriana Mucinska — “all employees and/or co-conspirators of Epstein’s,” according to the court papers. The documents show that Clinton flew with Epstein, “then suddenly stopped — raising the suspicion that the friendship abruptly ended ... “Epstein’s personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him ... and what appears to be Clinton’s personal numbers,” the court papers say. Allegations in the documents say Epstein threatened victims — including Edwards’ client Jane Doe — despite no-contact orders in effect. Epstein had Doe tailed by a private investigator as her trial date neared, the court filings say. One time, Doe was so frightened that she fled her home in the company of a retired police officer and was taken to a hiding place, according to the court papers. http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ 35 HOUSE_OVERSIGHT_011946

That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I’ve been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), learn about , it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trafficking Trafficked Athletes And now a new one I should have seen coming, Those very young, foreign models you see? Some of them were trafficked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory traffickers; Go to politically or economically unstable areas, locate 5'11”" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. it’s hard to think of an area of our society that doesn't admire seeing it’s most vaunted members with a model on their arm. While this observation does not imply that those people were trafficked, imagine how simple that makes it to approach a child or it's family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. I'm not shocked at traffickers using this method of promises to lure unsuspecting girls into slavery, I've seen it, read about it, studied it. I’m in shock that it flourishes in the most visible, 36 HOUSE_OVERSIGHT_011947

glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don’t drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery, she's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Sarnoff Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published “The Sex Trafficking Mode} Scout” warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries into the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as “models.” Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jeffrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS’s 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and “no criminal charges have been filed by any of his accusers” — although many have tried to serve him including lawyers representing Epstein’s victims, Brunel continues to hide behind his French citizenship to aT HOUSE_OVERSIGHT_011948

prevent depositions. “Trawling for 5°11" underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations.” Given his citizenship he also successfully avoided deposition in Epstein’s sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, “he did not respond to our interview request.” According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn’t considered a major industry player, it isn’t exactly bottom-shelf, either... Brunel isn’t involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source, Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a ‘scouting tsunami’ and MC72 is fairly well known for the strength of its international scouting. Model, Michael Gross’s 1995 book, describes Brunel’s activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. “Jean-Luc is considered a danger,” says Jér6me Bonnouvrier. “Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He’s always been on the edge of the system.” John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he’s cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps.” Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford's daughter, talked to the Wall Streer Journalmagazine. In that story “A Model Trade Union,” Ford describes herself as a “roving ambassador” to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. “In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women’s leadership group that was studying the issue of trafficking. “I said, ‘I can’t come talk about it, because | don’t know anything about it!’” Ford recalls. “But | went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models. According to Ford “‘the target age is 14 to 24, and so it’s similar to modeling.” | knew how to reach that market” she said, “It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls.” 38 HOUSE_OVERSIGHT_011949

http://slaverytoday.org/that-gorgeous-underage-ad-model-may-be-trafficked-and-owned- regulation-for-agencies-to-stop-child-sex-trafficking/ That Gorgeous Underage Model May Be A Slave: Regulation For Agencies To Stop Child Sex Trafficking First came the knowledge that slaves still existed and were present in larger numbers than ever before. Then the realization that a human being could be purchased within a few hours of my home for under $100. Now only a few miles away. In the following years I've been learning the myriad forms, places and types of slavery. The list keeps lengthening and with each new form (to me), I learn about , it knocks me down, one more time. Slavery Debt Bondage Sexual Slavery Child Brides Forced Labor Child Soldiers Adoption Trafficking Organ Trafficking Trafficked Athletes And now a new one I should have seen coming. Those very young, foreign models you see? Some of them were trafficked by model scouts who literally trawled through some of the most destitute and vulnerable people on earth for them. The same methods as other predatory traffickers; Go to politically or economically unstable areas, locate 5'11" beautiful young girls; buy them, import them, own them, use them. Horrible irony to have images that portray us to the world possibly be of slaves. It’s hard to think of an area of our society that doesn't admire seeing it's most vaunted members with a model on their arm. While this observation does not imply that those people were trafficked, imagine how simple that makes it to approach a child or it’s family anywhere in the world and offer them this in return for absolute control. All the traffickers have to do is pull out a magazine or phone with videos on it. 29 HOUSE_OVERSIGHT_011950

I'm not shocked at traffickers using this method of promises to lure unsuspecting girls into Slavery, I've seen it, read about it, studied it. I’m in shock that it flourishes in the most visible, glaring spotlight of our culture, the part that worhips and presents our current idea of beauty in almost everything we touch. These victims are on the most prominent slave block ever, emulated by our children, coveted by our culture-makers and our society, and standing in the brightest global spotlight in the world. In plain sight, reported on in numerous stories for decades and yet only escalating in usage until they've become the golden mean. We can quietly ignore the ones resold daily in our town, who made our clothes, chocolate, housewares, provided the gold on our fingers and necks, electronics in our hands, labor in our fields. Here, finally, are slaves we fantasize about being, emulating, allow our society to be shaped by, consider trophies. What will this say about us if we don’t drastically change it? All of it. Katie Ford walked away from an empire the first time she learned about slavery. she's working to change with this thing she recognized to be permeating the industry. That is courage. Regulating Modeling Agencies to Help Prevent Child Sex Trafficking Conchita Sarnoff Posted: 02/10/2012 8:49 pm In 2010, Jezebel, an online site, published “The Sex Trafficking Model Scout” warning about the dangers of deregulated modeling agencies in the U.S. Given the growing number of modeling agencies that transport underage teenagers from foreign countries tnto the United States and the growing sex trade of underage girls in the U.S. why does this industry remain deregulated? Since the advent of this business, modeling agencies have had free reign to scout teenagers from every state in the country as well as every nation in the world. Many of these teenage girls come from economically disadvantaged families and are offered none to very limited protection while traveling and working as “models.” Jezebel reported that Jean Luc Brunel, one of the cast of characters involved in the ongoing Jetfrey Epstein (a level 3 registered sex offender), eight-year-long case, has been working for over two decades with a succession of agencies in New York and Paris. According to media reports, Diane Sawyer produced a segment for CBS's 60 Minutes featuring a sex scandal that eventually led Eileen Ford (founder of renowned Ford modeling agency) to stop working with Brunel. Brunel's latest venture is the modeling agency MC2 based in South Beach, Fla. with satellite offices in New York and Tel Aviv. Since his agency is deregulated and “no criminal charges 40 HOUSE_OVERSIGHT_011951

have been filed by any of his accusers” — although many have tried to serve him including lawyers representing Epstein’s victims, Brunel continues to hide behind his French citizenship to prevent depositions. “Trawling for 5’11” underage teenagers to work for his agency, MC2, or anyone else who requests, Brunel is free to scout for very young girls without limitations.” Given his citizenship he also successfully avoided deposition in Epstein’s sex related cases. Like so many other reporters who have tried to report his side of the story when Jezebel contacted Brunel, “he did not respond to our interview request.” According to Jezebel: we spoke to a number of people who worked with his agency and while MC2 isn’t considered a major industry player, it isn’t exactly bottom-shelf, either... Brunel isn’t involved with the business on a day-to-day basis, although he owns an 85 percent stake in MC2. Instead, he does scouting for the agency and takes care of the international relations with other agencies, reports one source. Scouts scour the world for unrepresented teenage girls who could make it as models. They work largely unsupervised and are generally paid a headhunting fee for every girl an agency signs. Even when affiliated with an agency, as Brunel obviously is with MC2, scouts operate mostly independently and with little oversight. The company blog refers to Brunel as a ‘scouting tsunami’ and MC2 is fairly well known for the strength of its international scouting. Model, Michael Gross’s 1995 book, describes Brunel’s activities in Paris from the late 1970s onwards, when he worked for, and eventually owned, the modeling agency Karin. “Jean-Luc is considered a danger,” says Jér6me Bonnouvrier. “Owning Karin was a dream for a playboy. His problem is that he knows exactly what girls in trouble are looking for. He’s always been on the edge of the system.” John Casablancas, founder of Elite modeling agency said: I really despise Jean-Luc as a human being for the way he’s cheapened the business. There is no justice. This is a guy who should be behind bars. There was a little group, Jean-Luc, Patrick Gilles, and Varsano. They were very well known in Paris for roaming the clubs. They would invite girls and put drugs in their drinks. Everybody knew they were creeps.” Casablancas was a professional rival who was pushed out of his agency for questionable concerns. Katie Ford human trafficking abolitionist and Eileen Ford’s daughter, talked to the Wall Street Journalmagazine. In that story “A Model Trade Union,” Ford describes herself as a “roving ambassador” to help stop human trafficking. Ford sold her stake in the family business in 2007 to the private equity firm Stone Tower Equity. “In her new life as a nearly full-time, unpaid, roving ambassador for the cause her job is an outgrowth of her former work, rather than a repudiation of it, or an atonement. Her interest in human trafficking began when a representative of the United Nations called to ask if she would participate in a women’s leadership group that was studying the issue of trafficking. “] said, ‘] can’t come talk about it, because I don’t know anything about it!’” Ford recalls. “But I went, and after two hours, I knew why I was there. The way people traffic across borders is parallel to the way we recruit models, According to Ford “the target age is 14 to 24, and so it’s 4] HOUSE_OVERSIGHT_011952

similar to modeling.” | knew how to reach that market” she said, “It was the feeling of: There but for the grace of God... The girls who came to us could have been those girls.” 42 HOUSE_OVERSIGHT_011953

http://files.wallstreetfolly.com/wordpress/2007/10/jeffrey- epstein-doesnt-want-to-be-branded-as-a-sex-offender-for- life-and-no-hes-not-a-modeling-agency-secret-sugar-daddy- or-so-its-owners-say/ Jeffrey Epstein doesn’t want to be branded as a “sex offender” for life, and no, he’s not a modeling agency secret sugar daddy (or so its owners say) Posted by WSF On October - 9 - 2007 Jeffrey Epstein, the billionaire money manager who’s agreed to plead guilty to soliciting underaged hookers and go away for 18 months, doesn’t want to be branded a "sex offender" for life. Page Six says his lawyers are thinking about asking prosecutors to drop that requirement from his plea agreement: In a letter drafted, but not sent, to U.S. Attorney Alexander Costa and obtained by Page Six, Epstein’s lawyer, Gerald Lefcourt, writes, "Doing so will have a profound impact [on Epstein] both immediately and forever after. Not only will he be restricted to a wholly inappropriate penal facility, but he will be required for the rest of his life to account for his whereabouts.” Meanwhile, over the weekend Page Six said that owners of MC2 modeling, run by Jean-Luc Brunel — who’s also been accused of favoring underaged models in the past — claim that Epstein is not the secret deep pockets behind the firm, no matter what others say or speculate. 43 HOUSE_OVERSIGHT_011954

Epstein, .....reportedly gave "millions" to start MC2, which opened in October 2005 with offices in New York, Miami and Tel Aviv. One of the girls Epstein, 54, was accused of soliciting massages from was described in court documents as being just 14. "E equals MC squared .. . get it, like the equation? E equals Epstein. He just thinks everyone is too dumb to figure it out," said a model industry insider. "He’s a desperate old man that fantasizes and takes advantage of young girls." "Jeffrey Epstein has no ownership or involvement in our company and never has. Jean-Luc Brunel and | are the only two partners and owners of MC2 Model Management," [Jeffrey] Fuller said. [MC2 President] 44 HOUSE_OVERSIGHT_011955

http://www. washingtonpost.com/news/volokh-conspiracy/wp/20 | 4/04/2 | /eleventh-circuit-rules- that-discovery-can-move-forward-on-my-crime-victims-rights-act-case/ The Volokh Conspiracy Eleventh Circuit rules that discovery can move forward on my Crime Victims’ Rights Act case By Paul Cassell April 21 On Friday,the Ith Circuit ruled that discovery can move forward in an important Crime Victims’ Rights Act case that my co-counsel, Brad Edwards, and I are pursuing. The narrow issue before the court was whether prosecutors and defense attorneys could assert some sort of “privilege” to prevent crime victims from reviewing the correspondence that lead to a plea bargain. More broadly, the ruling means that the victims will have a chance to return to the district court and seek to invalidate a plea agreement that (we alleged) was consummated in violation of their rights. I hope that the case will ultimately set an important precedent that federal prosecutors can’t keep victims in the dark about the plea deals that they reach. Here are the important facts, taken from the 11th Circuit's opinion: The case arose in 2006, the 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 Doe No. 2, in June and August 2007. Extensive plea negotiations ensued between the prosecutors and Epstein. On Sept. 24, 2007, the prosecutors entered into a non-prosecution agreement with Epstein in which they agreed not to file any federal charges against Epstein in exchange for his guilty plea to minor Florida offenses (e.g., solicitation of prostitution). Not only did the prosecutors neglect to confer with the victims before they entered into the agreement with Epstein, they also concealed its existence for at least nine months. For example, the prosecutors sent post-agreement letters to the victims reporting that the “case is currently under investigation” and explaining that “[t]his can be a lengthy process and we request your continued patience while we conduct a thorough investigation.” On June 27, 2008, the prosecutors informed my co-counse!, Brad Edwards, that Epstein planned to plead guilty to the Florida charges three days later. But the prosecutors failed to disclose that Epstein’s pleas to those state charges arose from his federal non-prosecution agreement and that the pleas would bar a federal prosecution. As a result, the victims did not attend the state court proceedings. 45 HOUSE_OVERSIGHT_011956

On July 7, 2008, Edwards and I filed a petition alleging that Jane Doe No. 1 was a victim of federal sex crimes committed by Epstein and that the United States had wrongfully excluded her from plea negotiations. We also alleged that the federal prosecutors had violated her rights under the Crime Victims’ Rights Act (CVRA) — specifically her rights to confer with the government, to be treated with fairness, to receive timely notice of relevant court proceedings, and to receive information about restitution. The United States responded by claiming that it used its “best efforts” to comply with the rights afforded to victims under the CVRA, but that the act did not apply to pre-indictment negotiations with potential federal defendants. After Jane Doe No. 2 joined the initial petition, the district court (Marra, J.) found that both women qualified as “crime victims” under the CVRA. The district court later_rejected the government's argument that the act only applies after the filing of a federal criminal indictment. (I’ve written a law review article about the issue of how early crime victims’ rights attach in the criminal process, which can be downloaded here.) Among other relief, we sought rescission of the non-prosecution agreement as a remedy for the violation of the victims’ rights. To make the case for such a remedy, we moved for discovery of the correspondence between the U.S. and Epstein’s attorneys during the plea negotiations. Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the court should find that the materials were protected under the work product doctrine or, alternatively, should be protected under a new “common- law privilege for plea negotiations.” The district court first ruled that rescission of the plea agreement was a possible remedy under the act. The court then ruled that we were entitled to review the correspondence, rejecting all of Epstein’s arguments. On Friday, the 11th Circuit affirmed the district court's ruling that we could review the plea correspondence. At pp. 18-22 of its published opinion, the court concluded that there was no basis for restricting access to such correspondence when crime victims have a legitimate need to review it. The court rejected, for example, the work product argument because plea discussions are not confidential: Disclosure of work-product materials to an adversary waives the work-product privilege. See, e.g., Jnre Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors’ disclosure of their work product waived any claim of privilege. ... The court also declined to recognize a new privilege for plea bargaining, finding the relationship between prosecutors and defense attomeys did not need special protection: Asa last-ditch effort, the intervenors contend that “[i]f more is needed in addition to the plain language of Rule 410 to preclude disclosure of the correspondence to plaintiffs, it can be found 46 HOUSE_OVERSIGHT_011957

in the conjunction of Rule 410, the work-product privilege, and the Sixth Amendment right to the effective assistance of counsel in the plea bargaining process,” but this novel argument fails too. As explained above, Rule 410 does not create a privilege and the intervenors waived any work-product privilege. The intervenors concede too that the right to counsel under the Sixth Amendment had not yet attached when the correspondence was exchanged. Lumley v, City of Dade City, Fla., 327 F.3d 1186, 1195 (1 1th Cir. 2003) (“{TJhe Sixth Amendment right to counsel ordinarily does not arise until there is a formal commitment by the government to prosecute,” such as a “formal charge, preliminary hearing, indictment, information, or arraignment.”). The “conjunctive” power of three false claims of privilege does not rescue the correspondence from disclosure. . .. The Supreme Court has identified several considerations relevant to whether a court should recognize an evidentiary privilege—the needs of the public, whether the privilege is rooted in the imperative for confidence and trust, the evidentiary benefit of the denial of the privilege, and any consensus among the states, Jaffee v. Redmond, 518 U.S. 1, 10-15 (1996}—but none of these considerations weighs in favor of recognizing a new privilege to prevent discovery of the plea negotiations. Although plea negotiations are vital to the functioning of the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violated their rights under the Act. Moving forward, this case raises the important issue of what kinds of remedies are available for violations of the Crime Victims’ Rights Act. Our complaint alleges that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart plea deal they had reached with him to avoid public criticism of the deal. I am hopeful that in future district court proceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally-negotiated plea deal. Paul G. Cassell teaches criminal law, criminal procedure, and crime victims’ rights at the S.J. Quinney College of Law at the University of Utah. Before coming to Utah, he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C, Circuit and for Chief Justice Warren Burger of the Supreme Court, an Associate Deputy Attorney General with the U.S. Justice Department (1986-88), and an Assistant U.S. Attorney for the Eastern District of Virginia (1988 to 1991). Cassell joined the faculty at the University of Utah College of Law in 1992, where he taught full time until he was sworn in as a U.S. District Court Judge for the District of Utah in 2002. In 2007, he resigned his judgeship to return full time to the College of Law, to teach, write, and litigate on issues relating to crime victims' rights and criminal justice reform. 47 HOUSE_OVERSIGHT_011958

-------- Original message -------- From: Jolanta MODILINOS Date:15/10/2014 4:46 PM (GMT+02:00) To: Jean Luc Brunel Subject: Dear Jean Luc, Hope that you stay fine. As per our conversation about placement of her with you in NYC and Miami, she said she found some article in internet , which changed her position and she preferred to be placed with another agency.. lam so sorry, but people believes in media more than in us sometimes, what is sad! Warmest regards Jolanta Sadauskiene owner MODILINOS model agency MODILINOS models Parodos 7-4, Kaunas Sv. Stepono 7, Vilnius tel/fax:+37037323257 cell:+37069816103 [email protected] [email protected] www.modilinos.com EXHIBIT B HOUSE_OVERSIGHT_011959

From: "Vladimir Yudashkin @ 1 MotherAgency" Date:17/10/2014 10:46 AM (GMT+02:00) To: Jean Luc Brunel Subject: The situation with Liza Zazdravnih Dear JeanLuc, Unfortunately | need to announce that Liza Zazdravnih rejected signing the contract with MC2 in United Sates. Initially she intended to sign the contract, but later on she came across that article in internet about you involved in illegal activities with young models. This information somehow changed her intentions completely. she is ready to be a model and consider contracts with other agencies, but she has suspicions that you will force her to illegal activities and she made the decision to don't put her self in risk. Lets keep in touch. | will be happy to work with you next time if we have another right model for you. Im upset that it didn't work out with Liza Sincerely, Vladimir EXHIBIT C HOUSE_OVERSIGHT_011960

-------- Original message -------- From: Manuela - Mega Partners Date:17/10/2014 9:36 PM (GMT+02:00) To: Jean Luc Brunel Subject: MC2 Dear Jean Luc, I’m very happy to hear you’re coming to the agency with Vini so we can talk about us working with MC2 again. I don’t need to remind you that the sex trafficking allegations have stopped us from working with * your agency for the past 5-6 years — but as Vinicius is my friend, J will try to find a girl that already knows and trusts him to place with you. Thank you very much for the lovely bag and we’ll see each other on fashion week. Kisses, Manuela MANUELA W MARTINEZ Intemational Relations Phone: +56 21 3818.4800 MEG A Direct: +6511 3818.4827 Cell: +55 11 98668.0090 PARTNERS megamodelbrasil.com.br EXHIBIT D HOUSE_OVERSIGHT_011961

Original Message----- From: Lorraine <[email protected]> Organization: MC2 MM Reply-To: <[email protected]> Date: Friday, August 27, 2010 at 8:49 PM To: <[email protected]>, Jean Luc Brunel <[email protected]>, Pink <[email protected]> Subject: FW: Press Inquiry from AFP (Agence France Presse) Videographer--Michelle Stockman > > >-----Original Message----- >From: Michelle STOCKMAN [mailto:[email protected]] >Sent: Friday, August 27, 2010 11:03 AM >To: [email protected] >Subject: Press Inquiry from AFP (Agence France Presse) >Videographer--Michelle Stockman > >My name is Michelle Stockman and | am a video journalist for Agence France >Presse, the French newswire. We produce 1.5 to 2 min. videos that are >distributed internationally to broadcast clients in Europe and Asia, and >internet clients worldwide. In preparation for Fashion Week, my print >colleague and | are interested in doing a piece on trends in casting >models >of color. | was wondering if you could refer me to a model of color and a >casting director who can comment on her experience. > >My deadline is next week, so | would like to set something up for Monday >Oor >Tuesday. | can come to you as | am a one-person camera crew. When you >have >a moment, please let me know. I'd be happy to discuss with you over the >phone ahead of time. > >Best regards, >Michelle Stockman > > >Michelle Stockman >747 Third Avenue, 35th Floor >New York, NY 10017 EXHIBIT E HOUSE_OVERSIGHT_011962

>917-533-3261 >www. youtube.com/AFP > >Agence France-Presse is the world’s oldest newswire with journalists in >165 >countries. We publish worldwide in English, French, Spanish, German, >Portuguese and Arabic. AFP delivers the news to thousands of media outlets >worldwide from newspapers to magazines, radio and TV stations and online >services. |t reaches an audience of more than one billion people daily. >This e-mail, and any file transmitted with it, is confidential and >intended >solely for the use of the individual or entity to whom it is addressed. If >you have received this email in error, please contact the sender and >delete >the email from your system. If you are not the named addressee you should >not disseminate, distribute or copy this email. > >For more information on Agence France-Presse, please visit our web site at >http:/Awww.afp.com > EXHIBIT E HOUSE_OVERSIGHT_011963

Sent from Samsung Moble ---—- Original message --——- From: Michael Sanka Date: 12/12/2014 12:48 (GMT-05:00) To: Jean Luc Brunel Subject: Scouting Jean Luc, How are you? After so many years scouting for you and having a great network of agencies all around the world who enjoy to work with us, i wanted to let you know that we are on the way to lose everything we build and we are gonna have big problem now. Agencies, still want to work with us but parents don't want their daughters to come to us, because when they google your name and the agency name the only things they see is “Sex Trafficking"!!! It's impossible to sign a new girl and if nothing it's done i can tell you that in 3 months we we will not get any new girls and i don't see how the agency will work without new faces. All the agencies who know you don't have any problems with you since they all told me "We know Jean Luc for more than 20 years and all those years we had so many girls place with him who had better experience than in any other agencies who were representing them as well and we never had any problems whatsoever, all our girls had great carriers as a model when he represented them". | understand those agencies because it's hard for them to talk to parents and explain that it's not the truth when it's all over the internet. You need to have it stop and have the people write an official letter to say that if's not the truth... | will keep you posted of course but it's really bad for us and the scouting. Best regards Michael Sanka 3104021028 EXHIBIT F HOUSE_OVERSIGHT_011964

Attn: Scouting division MC2 We toak notes of your comments and the girls that you like on our website. We know Jean Luc Brunel and we always work with him since more than 10 years all those years and never had any problems. All the girls he represented from us never had any problems. they were working have great book work with good clients in editorial and campaigns and were well represented models. Now for all the new faces we have, we needed to talk to their parents to discuss about me2 and you interest to represent their daughters and of course they gougle il and saw all the bad articles about sex trafficking they were scared and | was myself speechless since we know that it's not tue bul it was hard for us to explain to the parents. So of course for the moment till all is claritied we can't place any new faces with you because the parents will refuse and it makes us look had to propose the girls to your agency. We are sorry but you really need to clarify everything, till then we will have to cease any collaboration and we will have to refuse lo lel you represent any of our models. Sure you understand. Sandra Petkanie Fox Fashion Agency www. foxmodel.com sew e-mail: toxoffice @ sezampro.yu - ee og eee Beog wetogorska 35 v. slan 12 Tel +381 11 9446414, tel Taw +381 11 3226202 EXHIBIT G HOUSE_OVERSIGHT_011965

10 11 i La 14 15 1€é 17 1% 20 21 Bae 23 25 Q As part of your employment with MC Square did you live in New York, for a time? A I'm sorry, but I take the Fifth. Q Have you ever heard any model of MC Square who at the time of being a minor, that means under the age of eighteen, made an accusation that Jean-Luc Burnel acted inappropriate with her? A Never. And that is something that I will not answer. And I said never because even when peoples come and ask me I will always say the truth regarding that. I know Mr. Brunel for the longest -- maybe eight years. And I always said what I know. I never saw and I never knew that he did anything. So I know that. And that's the truth. Never. I never heard anybody accusing Mr. Brunel or complaining about Mr. Brunel. Nething. Q That means -- that means at any time no model, no minor model came to you and said, you know, “Maritza, look what just happened to me", that, "something bad happened to me". A Maybe a model came and told me, "Maritza, look what happen to me. I don't have any money,” or "T doen't have a place to live"™. Or, "Look, I didn't get my ticket", or whatever. EXHIBIT H-1 HOUSE_OVERSIGHT_011966

43 MR. OBRONT: Well, I would object, because of circumstances. BY MPR. DAVID: Q But you said before that you never heard anything that would indicate that Jean-Luc Burnel behaved inappropriately with -- with any models, especially any minor models that MC Square may have had. Is that correct? A Yeah, I said what is the truth. Nobody cemplain to me. Nebody -- your question was very clear, has any girl came to you and complain about sexually, you know, involved with Mr. Brunel. Q Right. A And my answer was no. Nobody came to tell me. I never saw. I never knew. His personal life was net my problem. Q Do yeu have any actual knowledge, that is to say were you present or did you see with your own eyes, any minor models go with Jean-Luc Burnel to Jeffrey Epstein's home, or any party ef his? MR. OBRONT: Objection. THE WITNESS: T['m sorry, but I take the Fifth EXHIBIT H-2 HOUSE_OVERSIGHT_011967

COMPOSITE EXHIBIT | HOUSE_OVERSIGHT_011968

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M4 THE CHRCUIT COURT OF THE LIUENT a JUSOAL CRE UT . Aa rs ANS OO AllAbth GAD? COUMOT FLORIDA FALL TEAM, 2009 Trt STATE 8 FLORIDA + NFORRATION ron aan 4 NoMa Vac 1 RANG FER Fa: CP sabe ath "an Pad phe Fy woe SCHEMP ODER $55 1a: ; ; tena -aictamtay) © Townes be 1 fi THE NAME AND 8 THe AUTHORITY OF THE STATE OF FuORina: KATHERINE FE RRA RUNDLS, iste Adan cf he se ih deni acyg:, Fencing [a Owe S046 of Fina ithe Caurty <f Marre Disa by ee aegh Fen utter egnel asthe! Five Anomg, onder osih ilunnelta a abi Iai SOLE Toma Aw oe Gu ie Cem" Qo! Thre: Pe dm ICRA Phe Varnes oc UML YT, DO IPMART Se a eek a ey Gost a HOUSE_OVERSIGHT_011972

cham tas CoOWNT 4 WHRITZA VABGUE., bn o¢ Demeter May 2 TEM ond aun OC aCOR be are Cth Sate Toei es ote aw uy acd) adda, I oe Lae Fe Fi andsaecr ip GTAP OF .9e 3 coe ds avery the petperty GR ARE NCOELS UGA LLC ard JEAN RUC BEIMEL arco JEP FULLER be owner or crtcdee, wah pert of cee oe retreg rn as SaigreiSllC oe Migr mors, ah ine Fee Peeghes teow porary cy GeV Asal, dep K&RrhSoCtS US8 Lot water An LUC BRKEL gree ICES ELE ols ney lathe Pitcetty ot of e erm ronal ot lo a ppropioe he piepcy bo seed defaredet’a eee pa e'howrg 38 er paar. ed ened Be eo, gs idan O12 Oy eet hol Ra Son. cenbety 6 fe tart ihe Sod dain euchesne rede one provedad ant ejanel Ge cage9 wd dar) ont Fo sida ot Pecnda HOUSE_OVERSIGHT_011973

Lf wae toa COUNT 3 AC tha aiveqas Gsecinwt Slee homey widey calf, Cr ber odocraten rene MARITZA VASQUEL on o¢ belesor Mery 2) 20d acet bane 30 0008 nite Cord on9 Size akernad chduvcatity ao Sirius arene né erertg ts iocoud oc defied bs & aU? OS aq) fan Stal bs craagrs oo aesemlc cegerg cous cavidl wh ied bo dale on oe wcemsow owl EAR MODELS USA LLC ander JRE LU. BALE av3u: JEFF FIG LER. by tae oF Frode! orelermes, ropeceortsicre, of premmaes a wiyl fet ep baadakos let rue set wet da theebrchtem prec coe LI ROTM OF CURHESCY, fas apy apse asiye nt Sip Ove d cede [BEC CCD CET or more, ha Lye Ty oT ARDS ORS BA, OC anger JEAN LL EXUSEL ardor dEPF FULLER cere oo ebook Fe TC? Fu Slat comtare bho be ne Sabie o sech canes eta be wel orikad and ogame tha peor and ogi 9! he Steta al Para HOUSE_OVERSIGHT_011974

STATE OF FICRID A, C01 914 08 WRAL ADE: Peels btrae tome sed peated Seices we ihe Sema Fue Atkeesce ot the Herenth Funtal (scr cl Picea wl anes siptadara ope Pel ta hep bee duly recon, sapuchar tw 1 agate ag itt eta In depmnmie ace tebe apes aca whe ee heen seer ide hs Upurea wer RinAoth, unt APch ibis ange 3 a wllgeag: Ute eg atl ured heer duis [oeeasciedi ns LRT ab ne! “as ae A, a ee, ae fi aad 20 “hae Sete. Bap t 2 aes te 2 Se on Lise he th | oe Sthepe BR ame Sate ed 2 ” : wn Seer iwued abet ate ene a al ‘ wel HOUSE_OVERSIGHT_011975

= ad * A. SERRA ACEC ANU Oe fe i —— 4 ete 4. ee a x nd ape Fre LE PRG8 ond Bt tek et age near Saag ioe ae ee a reer rrr rr: AL. ateay 68 ee Rare gerade fel FOC "me DA. ia A SE EP lead — ’ y el hg fee eee OU Ce ee fA Wet, ia , ' Savi ie Elite yee oped ier Le gift fe oy eh Ls a Cal { Zhe td fief saute ected po see ited et Boer Hy | veaf ti i af ar _ Pee : og-eeien?® La « ¥ “as . atten ae ies, le? — . aa = madstibey fF gegevens f tte he on f, Te Bg ee ee eee EXHIBIT I HOUSE_OVERSIGHT_011976

COMPOSITE EXHIBIT J - VISA HOUSE_OVERSIGHT_011977

af Mormmelanal Mavwrity ge aura Migr Bary ros ONL BAM Gare Bam 4440 HOLLYWOOD BEA? Urre 2218 MOLES FI. 33001 —— ee en | Fes ates POR seme hut bees aie, mck fe Sie ie ie teeg SER WS5Sem web GE Thlr PEELOe GS She -eeeTIe! Re PATO eiish +E CUA vate Wes te err ema Pek iste sere: eos as peak ia ee eles tasn were gum Gsee paededebes om any ume: olereh Bits whe! Jaane 16 Sibi beites ghee. = evhitioees ee =e ~ dm the te py it dope en ET Bn ampeeyeeres an — Geren ki an real thie wie peetieqdet chiees mk 4: td Pita hig ee Cae boadlllniondl THIGH. CeO =F aepuGEne oF wesieso --f uesiwem. & Paces aoe ee ee oe eae he eid ieeel | taforraaranacon ire Tac ou we U8 LT LEMEM LY Dee OAT LCN WE va cERY= CLNTER 78 TAR WEL TTT T BALWT ALBANESE VE Odie -ogud « £800) ATS-s8208 "Sy Ter pion may eee Sete etaee rte Riepts kanp Gat @ vine on eR Acyarvibert cusmeubein Absit, @ar 0 Feit vine 00 rmmpldlontall, ik iene ieee ae Ve. Hecespre rac 11 tee BaGR7 REL Ee DOTS. Bee are « feah 68 bon We daelan yp cho harm — res eee eee ioe me eee. Tee LEFT PEPE Re AE PRES SPR Pee 1-797, NWotice of Action Bh Valid €2£0m 125/703 /2021 eo Se/30/ER84 Consauisgh=) FARES Ge chee 262s eeeeslat= Vou ain) atoe sed the eed Migsod qemiegs timp duimesiiete itis ain ewe ee Plas oe om rin. amey el en ee sa ear Sewee Suanera weal Piesee mem = miki 2 ochre OF Gin ceeh dere wil he ole EierS eee GATOR Eee Teh ied hie che Geaeed 2 — i an Claes Cornweiaie of 1. Pe sopereiciy aa Le Cipees crass bee rae BP ee oF eerie fl Chews ee ove F701 (les lari} N HOUSE_OVERSIGHT_011978

SUPPORTING DOCUMENTS EXHIBIT? §= Several press and media articles documenting ihe rise of South Beach as one of the United Sloaies’ main fashion capitok. EXHIBIF2 Press articles regarding the mocdek and actresses who were bolh discovered by and careers were launched by the baneliciary. Jean Luc Brune. EXHIBIT3 Severol officles regarding the preshgious reputation of Kann Models as lormerty one of the ward's laading agencies. EXHIBIT4 =A fist of all of MC2’s clients, including several high-profile campaigns featuring some of MC2's fashion models. as well as several press clippings regarding this prestigious and reputable modeling agency. EXHIBITS = The beneficiary's. Jaan Luc Brunel. impressive curiculum vilae. vetdying his iremendous accomplishments in both ihe fashion and modeling indusiries, EXHIBITé Several arlicies regarding the 2004 Models New Generation Contest (including franstations) as well as the beneficiary's leading role within this presiigious modeling evert. EXHIBIT? Several press arlicles regarding fhe prestigious 2006 Models New Generation Competition [including translations]. as well as the beneficiary's Jean Luc Brunel, teading role within Ihe event, EXHIBT& Letter of Claudia Midolo. President of Modetwork. a renowned modeling agency. EXHIBIT? Letter of Ala Amoniova. Drector of Figaro international Management. EXHIBIT 10 Several press artictes reliecting the prestige and high circulation rates af the mentioned magazines and periodicals which have featured ond covered the modeling events which Ihe beneficiary. Jean Luc Brunel, has organized throughout ihe years. EXHIBIT 11 = Intormation regarding ihe exiramely successful and prestigious modeling and lasmon association. International Model Talen! Association (IMFA}, HOUSE_OVERSIGHT_011979

mc?’ MODELSMIAM| July 25, 2014 Department of Homeland Security United States Cilzenship and Imrnigralion Services Vermont Service Center 30 Houghion Street saini Albans, ¥T 05478 RE: 1-127, Patition for a Nonimmigrant Worker 0-1 Extracrdinary Ability os an Art Director and Talent Coerdinatar Petitioner, MC2 Medels Miomi, LLC Beneficiary: Jean-Luc Didier Henrl-Rene BRUNEL Dear Sir / Madarn: Tre present letter and ifs enclosures ore submilied in supporl of the altached 0-1 petition of MC2 Modek Miami. LLC. on behalf of Mr. Jean Luc Brunel. The petition is based upon Mr. Brunel's standing as an “Alien of Extraordinary Ability in Arl Direction and Talent Coordination.” Kindly note that Mr. Brunel currently holds O-1 status with our organization. The Sovih Florida area and Miami Beach in Panicular have become a mecca for the fashion and modeling industries. As a result, many of the largest intemational modeling agencies such as Ford, Elite. and MC2 have opened offices in South Beach and the area has become one of the most important in ihe modeling industry In faci, Miami Beach has become second only lo New York City in terms of employment opportunities for fashion models in ihe United States. Atlached as EXHIBIT 1, please find several press and media articles documenting the tise of Soulh Beach as one at the United States’ main fashion copilals. In 1996, our company. MC2 {formerly Karin Models), established an oilice in Ihé heart of the historic Ari Deco District of Miami Beach. “South Beach” has uly become one of the world's modeling Capitals and we are pleased io be a patoli Our agency nos developed a highly distinguished repulation in ihe modeling indusiry, We specialize in representing numerous models of internolional acclaim. Having discovered faces such as Christy Turlingion, and moided ihe careers of celebrilies such os Sharon Stone, Esielia Waren, Milla mace nodels mant « 1674 allon toad = sute 500 » miami beach fl 44144 30D 672 A300 + faz 305591 8330 = adminvstratinn 305 67? 7672 » tax 305 672 643a2 mo2mm wun HOUSE_OVERSIGHT_011980

Jovovich, Jeny Holl and Rebecce Ramin. who is curently stoning in fhe award- winning ABC felevision senes, Ugty Betty, MC2 models are among the most soughI offer in the industry, os evidenced by the coliber ot their commercial and echtorial bookings. Many of our fashion models have graced the pages of leading fashion magazines of the United States. Europe, Latin America, Alnica, and Australia such o% Vogue. Teen Vogue. Fle. W. Glamour. V. Martie Clgire. Sufface and Cosmopolitan os weil as many more throughout the world. In addition to our Miami Beach office. MC2 Models has offices im New York City and Tel Aviv, israel. As Ariisiic Dsector and Talent Coordinator for MC2 Models Miarry. LLC. Mr. Brune wil be responsible for overseeing ihe ortistic aspecis of the agency. By overseeing ihe ort department in the agency. Mr. Brunei wall direci the visual marketing of ihe models to clients, focusing on tne images placed an both the model's Composite cards and thew portfotios. Soth of these marketing tools are crucial in morketing fashion modes to their appropriale calaleg. editorial, of medio chents., As Aslistic Drector and Iglent Coordinalor, Mr. Brunel will also coorchnoie the painng of fashion models with a particular Photographer. Clients for the agency include o mytied of fashion Publicalions, retail stores, consumer product companies. and fashion houses io name but o few. Recruitment of talenied arlistic photographers who have on excetient understanding of the “ins and ouls” of ihe modeling and fashion mdustry is critical to the successtul running of a fop-modeling agency such as MC2 Modes. Mi. Brune! will also continue with his amazing fact record of discovering ihe world's greaiest talents and beauties in order fo sign them with MC2 Modek. Mr. Brunel wil continue to travel around the world looking for new talents, and to agencies around the word in order to establish relationships with those agencies and allow MC2 Models Miami. LLC 1o represent them in the Uniled Siates. Mr. Srunel’s impressive qualifications as an Arl Director and Talent Coordinator, establish eligibility os to the reguiotory standards for such classification os 4 top professional in his field. Mr. Brunel meets the O-! critena as an individual of extraordinary ability in the Aris and Entertainment field as well as Q business entrepreneur. MC2 Models Miami, LLC is Presently seeking a sophisticated art ditecior ond taleni coordinalor. After reviewing his expenance ond accolades. we are confident Ihat the beneficiary, Mr. Jean Luc Brunel, will perform scicf function with outstanding ski and professionalism. LMR, BRUNEL'S QUALIFICATIONS AS THE BENEFICIARY In addition tc Jean Luc Brunel's extensive business qualifications, his “oreer as an individual wilh artistic vision and creative lalents Qualifies him as an 0-1 atten in the Arts and Entertainment Field His alt- encompatiuna expenence as an Art Drector, Talent Coordinoior. international entepreneu ond business HOUSE_OVERSIGHT_011981

‘eader in the modeling. fashion. entertainment Public relotions. restaurant, and tourism industries has made Mr. Brune! internationally renowned in nose fields. Among his various accomplishments throughout his career are the successful modeling agencies he has founded both in Europe and in the United States. For example, in 1978. Mr. Brunel founded and grew Karin Models Paris from the ground up to become oa lgad-market agency with a world-wide presence. Capturing a sirong market share in Paris, Mr. Brunel successfully created Karin Modeis as a platform for marquee cllents to obtain sophisticated public retations services and important modeling contract opporiunities. Mr. Brunel's success was 50 greai wilh Karin Paris that in the next ten years, he founded Next Model Management in Los Angeles, California in 1980, Nexi Model Managemen in Miami, Flotida in 1982, Mode! Management Group alse in Miami, Floricia in 1986, and Rebecca Commercial Casting in New York City. in 1988. The loiter one was opened as a talent and casting agency for performers. offering services such as voice-overs, television, and cinema advertising work. again. successfully carving oul a niche by which to make his mark and achieve bold commerciai performance results, Although Mr. Brunel later sold his rights to Next Management io Faith Kalas in 1989, whe parinered with Joel Wilkenfeld a couple of years later: NEXT represents some of the mosi prestigious women and men in the fashion world today. Star faleni includes renowned fashion models Molly Sims, Doniela Pesiova, Audrey Quock. Yamila Diaz, and Malgosia Bela. NEXT continues to mainiain on infivential international force in Ihe foshion and modeling industry ihrough its fully operational offices in New York. Los Angeles, Miami. Sao Paolo, Montreal, London. and Paris. as well as iis affiliates in Milan ond Australia, Because of sirong revenue growth and successful business perlormance. as a resull of his arlislic vision as an artislic director and tateni coordinator. Mr. Brunel founded ihe very successful Karin Models of America in New York Cily and Karin Models USA in Mami Beach. Mr. Brunel's commercial ventures in opening Karin agencies in Pars. New York, and Miami have been oxiremely successful. generating combined annua! revenues of twenty five (25) million dollars. Eveniually. Mr, Brunel kcensed the Karin nome to agencies in Israel, Denmark. Germany, and Span, Mr. Brunel's extraordinary ialanis are not only limiied to launching successful modeling businesses. but also in discovering and launching the careers of some of ine world's most successful models. Mr. Brunel has launched the extremely successful careers of supermodels such as Chrisly Turtingion. Rachel Hunter, Sharon Stone, Monica Bellucci, Estella Warren, and Chistina Semonnovskaya. These women all proceeded to become some of the mos! phoiographed inlernational cover models in the word. appeoring on thousands of magazine covers worldwide and spanning many years. ASO resu't of his teputalion as 4 highly visible, sitategrc networker who cuilivales and conducts business in a global environment and brokers lucrative deals, many HOUSE_OVERSIGHT_011982

lop players in the fashion and entertainment field requested that Mr. Brunel function as iheir exclusive agent ond representative. Some of Ihese top former and present professional supermodels in the fashion field include. Naomi Campbell, Christy Turlington, Rebecca Romijn, Mila Jovanovich, inez Sasire, Melanie Thierry, and Jerry Holl. Attached as EXHIBIT 2, please find prass articles regarding ihe modek and actresses who were both discovered by and careers wére lounched by the beneficiary, Jean Luc Brunel. Additionally. aHached as EXHIBIT 3, please lind several articles regarding ihe prestigious repuiation of Karin Models as formerly one of the world's leading agencies. Most recently in October 2005. and after his reign with Karin Models, Mr. Brunel launched the prestigious MC2 Model Managemeni wordwide with offices in New York, Miami ond Tet Aviv. Mr. Brunel staried ihe high-profile MC2 Model Management in order to represent high fashion models in a boutique agency setiing. MC2 Model Management is aready being lauded by fashion insiders as “one of the hottest agencies in Norlh America” as well as “prominenily positioned lo be one of the major players of the Zeros becouse of its insider relationships wilh the most influential photographers cround.” We invite you 10 visit www.mc2mm.com in order to view the high-caliber of models, MC2 represents Some of iis most recent successful bookings include liu Dan's exclusive coniraci os the foce of the Fall 2007 Guess Campaign and Sammy Jo's Cover story for Cosmopolitan Magazine. Aitached as EXHIBIT 4, please find G list of all of MC2's clients, including several high-profite campaigns fealuing some of MC2's fashion modiets. as well as several press clippings regarding this prestigious and reputable modeling agency. Jean Luc Brunel's entrepreneunal spirit is not only contained to the freld of ars, beauty. and fashion. In 1970, as o result of his business insight, Mr. Brunei founded and grew Jean Luc Relations Publique, which specialized in press and promotions for tour operators and restouranls in Fronce. During his work through Jean Luc Relations Publique. Mr. Brunet represenied vorious key clients and collaborated on numerous prestigious events. Some of the presligious events include: Air Tour and Dare Voyages. Jean Luc Relations Publique also promoted and markeled La Tour D'Argen. a three-star restaurant owned by Claude Terrait and. “The Go-Between", a motion picture by George Losey. Ofher projects taken on by Mr, Brurel through his public relations company wos his work os product ageni for Jean Claude Killy, 1968 Winter Olympic Gold Medolisi skier, fo promote Vail, Colorado in France tor tourism potential and ako directed all of the promotion for Finland's Ministry of Tourism, tn 1975. Mr. Brunel iurther invesied in the Food and Hospitality market by creating ond developing "El Mono Desnudo"- a legendory, high-end ber on the ibenan Peninsula. This bar was known throughout the peninsulas extremely exclusive and attracied a celebrity clieniele that included actress, Ursula Andress, and lhe Duchess D'Alba. Alached as EXHIBIT 5, please find the beneficiary's, Jean Luc Brunel, HOUSE_OVERSIGHT_011983

IMpressive cuniculum vitae. verifying his ttemendous accomplishments in bolh the fashion and modeling industries. Il, EUIGH FICA N Y AB THE ARTS Under the Miscellaneous anc Technical immigration and Nationality Amendments of 1991, pelitions for classification as an Alien of Extraordinary Ability in the Arts must be supporled by evidence of “dislinction". According to 8 CFR §214.2(0) (3) (i). “dislinction” means a high level of achievemeni in the field of arts as evidenced by a degree of skill and recognition subsloniiaily above that ordinarily encountered to the extent thal a person described as prominent is renowned, leading, or well-known in the fields of arts, This evidence may consist of proof thai the alien musi be recognized as being prominent in his field of endeavor as demonsirated by the folowing according to & CFR §214.2{0)}(3} {iv}: A. Evidence that the alien has been nominated for or has been the recipient of significant! national or Inlernational awards or prizes In the pariicular fleld such as an Academy Aword, an Emmy, a Grammy, or a Director's Gulld Award, or B. At least three of the following forms of documentation: (1) Evidence thal the allen has performed, and will perform, services as a lead or starring participant In productions or events, which have a distinguished reputation as evidenced by critical reviews, advertisements, publicity releases, publications contracts, or endorsements; (2) Evidence that the alten has achieved national or Infernational recognition for achievements evidenced by eriiical reviews or ofher published materials by of about the Individual In major newspapers, trade journals, magazines, or other publications: {3} Evidence that the alten has performed, and will perform, In a lead, staring, of critical role for organizations and establishments that have a distinguished repuiction evidenced by articles In newspapers, bade journals, publications, or testimonials: (4) Evidence thai the alien has a record of major commercial or critically acclaimed successes os evidenced by such Indicators as litle, rating, standing In the held, box office recelpts, mation picture or television ratings, and other occupational achievements reported In trade Journals, HOUSE_OVERSIGHT_011984

major newspapers, or other publicotions: (5) Evidence that the alien has recelved significant recognition for achlevemen!s from organizations, critics, government agencles, or other recognized experts In the field In which the alien la engaged. Such testimonials musi be In a form, which clearly Indicates the author's authorlty, expertise, and knowledge of the allan's achlevements: or (4) Evidence that the afien has eiffer commanded a high salary o¢ will command a high salary of other substantial remuneration for services in relation to others In the fleld, as evidenced by contracts or other refiable evidence; or C. if the criteria In paragraph (0)(3)(1v) of this section do not teadily apply to the beneficiary's occupation, the petitioner may submit comparable evidence In order to establish the beneficlary's eligibility. EVIDENCE THAT THE BENEFICIARY MEETS AT LEAST THREE OF THE PFRONGS OF THE 1A R.SUBSECTI The fist prong that ihe beneficiary solisfies is 8 CFR §214.2{o3)(tviBy 1). which requires evidence that the allen has performed, and will perform, services as a lead or staring participant in productions or events which have o distinguished reputation as evidenced by ceutical reviews, advertisements, publicity releases, publication contracts, or endorsements. As a result of Mr. Brunel's combined expertise in fashion and tourism. he Gecided to create Latin Model Pageants, now known os Models New Generation. fo cross promote these key industries with international! business and investment opportunities. Mr. Brunel has promoted ond judged various modeting coniesis throughout South America including modeling contests staged in countries such as Peru, Ecuador, Brazil, Argentina, and Chile. Conceived in 1987, tne Lalin Model of Ihe World eveni was a high-end modeling and enterlainment produci ihat appeated io upscale international audiences. reaching nearly 400- milion television viewers worldwide. Throughout his hislory as a major infernahona: event promoter and artistic and talent coordinator, Mr. Brunel has orchesirated mulfi-foceted public relations, advertising and media campargns that incoiporated television, magazines, Programs. newsletters, and promotions, becoming nofubly lucrative for vonous major brands as a promotional teal. Mr. Brunel's acule knowledge of markeiing and promoting skills has furned his various international events into highly successful arhstic and business ventures for vanous major brands Latin Model Pageéanis offracied major brands as HOUSE_OVERSIGHT_011985

sponsors. such as American Aiknes, Ray-Ban. Coca-Cola, Proctor & Gamble. and Revion. Mr, Brunel's has continued his ventures as both a promoler and panel judge when he founded and created the international modeling contes!, Models New Generation Ihat tock place in Guayaquil. Ecuador in 2004. Mr. Brunel sat on a panel with ihree other professionals in the fashion indushy and judged over forty-nine young women from over North and Soulh America. Asia. and Europe. After len days of harsh competition, Jean Luc Brunel crowned the winner, Alyne Weber. a fifteen year old from Brazil. whom as a result of coming in first place was awarded over three hundred thousand dollars worth of modeling contracts. The city of Guayaquil, Ecuador was also thrown inio the international spotlight as the hos! city for fhe modeling contest. Ihe Modals New Generation was broadcasted on numerous television network channels including. Fashion T¥, which transmits to over 202 counties ihroughaui the globe, the entire Association of Television Channek in Ecuador, Nalional Television of China, and Rede Globo, Brazil's largest and most popular television network. AHached os EXHIBIT 6. please find several arlicles regarding the 2004 Models New Generation Contest os well as ihe beneficiary's leading role within this prestigious modeling event, AS a result of the tremendous success of the firsi Models New Generalion that iook place in Guayaquil. Ecuador in 2004, Mr. Brunel organized ihe second Model New Generation Contes! which was held in 2006 in the Ecuadorian capital of Quilo. In order to selaci only the very best new models. several preliminary. qualifying shows were held in different countries of Lofin Americo including Bolivia, Panama and Peru. The final contest was held ir: Quito, Ecuador al the hisloncat Ptaza San Francisco. Mr Brunel sat on a panel wilh three olher protessionols in the fashion industry and judged over forty-eight young women from twenty-eqghi different countries from Norih and South America, Asia, and Europe. After ter days of harsh competition. Jean Luc Brunel crowned the winner. Ginia Lapina. an eighieen year-old. from Latvio, whom as a resull of coming in first place was awarded over three hundred thousand dollars worlh af modeling contracts. The city of Quito, Ecuador wos also thrown into the international spollight as the host city for the modeling contest. Again, just like the immense media expose given io the first Models New Generation competition of 2004, the 2006 Models New Generation competition was broadcast on numerous television nélwork Channels wncluding, Fashion TV, which tiarsmils to over 202 differen! countnes fhroughoul the globe. the entire Association of Television Channels in Ecuador. Nahonal Television of China. and Rede Globo, Brazil's largest and mos! populor fetevision nelwork. Altached as EXHIBIT 7, please tind several press arlicles regarding the prestigious 2006 Mode Neve Generation HOUSE_OVERSIGHT_011986

Competition. as well as Ihe beneficiary's Jean Luc Brunel. teading role within the event. The 2006 Modek New Generation program was broadcast in over 202 countnes Ihroughout the word. Mr. Brune! has performed and wil mosi definitaly continue to perform services os a leading porlicipani in modeling events, which have © distinguished repuiation and wil bring more public inlemational ight io MC2 Models. For the above-mentioned reasons, Mr. Brunel satisfies INA §214.2(c) {3) [iv] (B}(1). The second prong thot the beneficicry solisties is § CFR $214. 2(oM3ivBN2). which requires evidence that the allen has achieved notional or Iniernational recognition for achievement evidenced by crilicat reviews of other published materials by or about ihe Individual in major newspapers, trad¢ journals, magazines, or ofher publications. Mr. Brunel holds an international reputaiion as a visible. stroiegic networker who is able io cullivate exper! relationship management skills in order fo conduc! business in o global envaonment and broker lucralive deals. Mr. Brune! has a long hstory in marketing ond odvertising major fashion campaigns. throughoul hs twenty-five year career in ihe fashion business. Mr. Brunel has developed workiwide exclusive modeling and cosmehc campaigns. Some of inese Major cosmetic compaigns include: Bio Therm with supermodel Bie McPherson. PHAS with Rebecca Romijn. Chrstian Dior with Chssting Semoannovskaya, Margret Astor wilh Monica Bellucci. Chane! with Patricia Von Rickenheim. Angel Feriume wilh Thierry Mugler. and Cacharel Perfurne with Alda Ballesita. Mr. Brunet has oo developed major fashion campaigns and has developed campaigns and exclsive coniracis with some of ihe world’s top fashion designers such as Yves Saint Laurent. Chanel, Christian Dior, Gucci, Prada and More Jacobs Piease see ihe enclosed tetie: af Claudia Midolo. President of Modelwork. a renowned modeling agency. EXHIBIT 8. AS o talent coordinator, Mr Brunel's success can and should also be measwed wilh ine successiul careers ine mode’. whose career; he launched, have achieved As slated above. Mr Brune! has dscovered and represented yorious super models throughout his career. Chrisly Turingfon. who was discovered by Mr. Brunel. has personiliad unatiected beauty. representing Calvin Klein's tragrances since 1987 Turlington, os well as another model represented by Mr Brunel, Naomi Campbell, became one of the lew supermodel, who managed fo make an easy transilion from the haute glamour of the 1980's to the relaxed simplicity of the following decade. Throughout hei exiensive career. ond os a resull of Mr, Brunel's “Fashion Savvy Eye”. Christy Turlington bas graced ihe cover of hundreds of lashion magazines, such as Cosmopolitan, W. Vogue, Shape. Fiiness, Ele. Bazgor. Marie Cloire, Harper's. HOUSE_OVERSIGHT_011987

Esquire, and even Time Magazine. Please see Ihe enclosed letter of Allo Amantova, Director of Figaro Internalional Management. EXHIBIT $. In addition, ihe modeling events {hat Mr. Brunel hos been organizing throughoul the years receive not only national, but also international atiention and appear in multiple publications around the world. One of the mas! recent events he organized, the Models New Generation contest, which took place in Ecuador wos publicized and transmitted by vanous lelevision networks ond appecred on mulliple newspapers and magazines. among them Globo Television Networks in Brazil. Fashion TY which is broadcast into 202 countries throughout the word. £] Universo, Cosas. La Razon. El Diario, EF Telegrafo. Notinorle, Exira. Hoy. El Gran Guayaquil FE! Comercio. Semana. and 8 Lideres. to name a few, These major publications have a large subscription rate which numbers in the many millions of readers. Atlached as EXHIBIT 10. please find several press arlicles reflecting the prestige and high ciculalion rates of the above-mentioned magazines and periodicals which have featured and covered the modeling events in which the beneficiary, Jean Luc Brunel, has organized throughout the years. Hence the beneficiary satisfias INA §214.2(0}(3) {iv](B)[2} for having achieved noi only nationat bul also intemational recognition for achievements in the modeling indusiry, by having hs work published in major newspapers and magazines ihroughoui the world. The third preng thal ihe beneficiary satisfies is 8 CFR 6214, 2/0 3HivHBH4). which requires evidence that the ofien has a record of major commercial or crilcally acclaimed successes as evidenced by such Indicators as tHe, rating, standing in the fleld, box office recelpts, motion picture or television ratings, and other occupational achievements reported in trade journals, major newspapers, or other publications. One of ihe main reasons ihai Mr. Brunel has been able jo not only survive. but abo be extremely successful in the ever-changing word of fashion is his abiity to identify and recruit star-quality folent. As a resull of his ability to scout major talents, Mr. Brunel was invited fo become oa member in one of the fashion industry's mosi elile and important assaciations. the Iniernational Model Talent Association (hereimnalter IMTA). The [MTA is an intemational association of Iraining cenlers for models and falent. IMTA gives aspwing modeb. actors, singers, and doncers speciocutor opporiunilies lo showcase their potential talents in trani of fon fashion and totent agents from ihe major markets of ihe international fashien industry. IMTA also provides ifs association members valuable marketing fips and nelwartking events wilh agents and scouls from around ihe ward. Severat al todays up and coming actors and models have been discovered at HOUSE_OVERSIGHT_011988

IMTA; some of ihese discoveries include world-renowned actors such as, Elijah Woods. Ashfon futcher, Katie Holmes. Eva Longona. Jessica Biel, and Sean Wiliam Scot. Attached as EXHIBIT 11. please find information tegarding the extremely successful and prestigious modeling and fashion association, IMTA. Addilionally, please find several pages from IMTA's afficial website documenting {heir discovery of the above-mentioned A-list actors and aciresses, whose membership in IMTA proved io be ihe launching pad for very successful and highly profitable careers in the film industry. Furthermore, as previously mentioned. Mr. Brunel has lovnched the successiul careers of many internationally renowned models, who have been featured and still cre in mony intemational and national fashion magazines. In addition, his commercial ventures. especially MCZ Model. formerly Karin Models, have been extremely successful generating combined annual revenues of twenty five (25) million dollars. Currenily MC2 is one of the most successtul and well-known modeling agencies in ihe world. Mr. Brunel is one of few people in the modieling business {hai have achieved o similar standing and have been able io maintain it for over twenly-live years. For the above-mentioned reasons. Mr. Brunel satisfies INA §214,2(0){3) [iv] [B) {4}. JARY MEET ¢ The pelitioner has submilied a plethora of evidence regarding Mr. Brunel's experience in the fashion modeling industry. Mr. Brunel's has esfablished MC2 Models, formerly Karin Models, which is presenily one of the major iniemational modeling agencies, wiih combined annual revenues of twenty five million dollars. Only someone with Mr. Brunel's expertise and sirong sinve for success can achieve such injemational acclamotion in the indusiry and been able io maintain his siatus for over twenty-five years. Mr. Brunel is lhe one responsible for ine launch of numerous supermodels’ careers. which have been maintained in ihe spoilighi fer several years. He has worked wilh renowned fashion designers and photographers, who have trusted his work and intuifion. In addhlion, Mr. Brunel has aichesirated many internolional and national successful fashion events thal have received inlemoational acclamation. For the above-mentioned reasons. Mr. Brunel in oddifion lo meeting al least three of the criteria of 8 CFR §214.2(0)(3){v)(B). he also qualifies under A CFR §214.2(0)}[3}{iv}(C) tl. CON { tis clear from the evidence thal Mr. Brunel is eiginte tor classification as an Alen of Exirgordinary Ability in Arl Direction and Talent Coordination based HOUSE_OVERSIGHT_011989

upon his meeting the eligibility requirements under the Immigration and Naturalization Act 101(aj{15){O}(i) and 8 CFR 214,2(0). Mr. Brunel's successful career proves that he is a promineni, leading. and well-known person in the field of arts. Mr. Brunel's extraordinary ability in the field of arls, in which he wil continue io work in the United Siales, has been demonstrated by sustained national and intemational acclaim. Based on ihe foregoing, we respecituily requesi your kind consideration and favorable determination of this petition, in order to accord Mr. Brunel the classification as an Allen of Extraordinary Ability in Art Direction and Talent Coordination. Again, kindly note that the beneficiary, Mr. Jean Lue Brunel, has held O-1 status in the past. Wherelore, for the above-siated reasons, we respectfully request your favorable adjudication of the O-1 nonimmigrant visa petition suomitied by MC2 Models Miami, LLC on behalf of Mr. Brunel. If you should have any questions or require any additional documentation, Please do nol hesilate to confact our office. Thank you very much for your kind alfention regarding ihis matier, Truly Yours, HOUSE_OVERSIGHT_011990

Uscis H Vermont Service Center 7 Lower Welden Street &. Albans, ¥T 0g479-0001 RE: 0-1 Non-immigront View Petition on bebalf of Jean Lac Didier Henrl-Rene Brune! 1 write this letter In arong support of Mfr, Jean Lue Brine! applicat:on for & non-immigrant vise to this country. | ue currently Ammiloistratore Unico fm Studio Pp. 1 have been asked to review the professional eredentlals of Ma. Brunel, and it is my professional opinion that Mis. Briel fa an Art Director and Talent Coordinator of extraerdipary who ranks among the xmall perrentege of fareign people at vcr} top of his field. 1 have seen first-hand Mr. Jean Luc’ cpecial expertise in the field, including esting, production, coordination, and art direction for shoots. Mr. Brune] is considered by those in our indumtry to be an extraordinary creative director talent, particularly for the fashion and related industries. In gay persona! declings with Mr. Jean Lae Brunct, [ found him to he thoroughly professional and capable of being utilieed in connection with a wide range of creative subject matier on any amignnient. He bas the intuitive ability to provide just what's needed in eonacction wih any particular creative process and passesses excellent artistic ohinagement and operational skifls that oome from his years of experience. Many people do net understand that behind every sececssful advertising campalgn and fashion shoot there ere creative men and woraen who are making sure that the business operates efficiently by noardinating different tasks betwecn models, photographers, and managing creative teams. | can honestly exy that Mr. Bruncl continually prove. himself an extraordinary talent im his Held. L offer an aninitigaied endomement for Mir. Jean Luc Brunel regarding bis visa gpplication ga @ person of extraordinary ability. There ip po doubt in Tay mind thet he populsrity end ability in the field will only cantinue to Proeper in years to come | ah HOUSE_OVERSIGHT_011991

a7 16/14 vega Vergiont Genace Center 9h Lower Welder Bireet Oe Abans, Vi 05479-0000), RE: 1 Now inerrant View Feichen on bens! of Jear (ie Brune Dear Ser or Madazi 1 ene Ge ter io atreng suppor of Mr ween Lic Brunet appheaton ey a8 Pen tminigyant visa te this country | ato currently working as an Agent ot Two Management in Low Angries Bored upan my sianding in the feld af the Gate indusiy | am frequently cated 16 ealuaty the credentials of other profeenonals op the Geld | hava been aaked to teeter the professore! credentials of Mir, Jeon Loc Brome te oy profedeicnal opinicn, eas! upon me persone! and profesional kncetaigt of bir. Bruneis tobents, that Mr. Grane w an art director of cxtrno-cinary atdiee who ranks among the sinall percentogp of forvign pecéewstona!s at very tep of hue fictd. T preety edumry Jean Luc Brunet and ‘uot i) 8 plasure w werk etth Gorn a tented pervect. JFuriggng fe che high profile euecesa of the companies wih srich he rqgule Works, clearly fam ect the ont one eho appreciston his tale, Hie riodzlal have apgened in amy of the warlds moat pupular publications, reechng Mieraly vollione $f amen tHe is purticularh famouse fur his work m loshicn, atiwertirg and edaucsoel works he coniiiyton to major chants. such a6 Calvia Micin, Onecl, Christian have @ecuredd hia @ position as one of the lemdmg High (eehemn ast Gercctaes worinag today. Jemn Ler Branel is the comsucomeal prefeeetonal wien it comes to the art of shies and his work ee: Cieplayyd in work! se most ete magemnes A trues erie. hee Geunscilied fo the mtiefectio;n of the chant on every eccasen Although Mr Grune cmt thr heghest ctpeneetion for hes werk. be Le well worth the cost. j My .tan Lex Brant! © unquestionably a: iievfucl of eatracibnam lalent. exer, iniernationl eclkevernent and ecknaarbedgrictt) Shoald you haw ane quesivess regan, Mr. Brunel e eutruardinar: absty. plese foc! free to contact mer ‘Thank you for sour aftenven and ronwderation. HOUSE_OVERSIGHT_011992

GREGKADELSTUDIOS Wt treed Bd fc new yooh Spt E713 z¥0 W274 Lied EARLS STA. RE: 0-2 Nan-inepigrant Vie Petition on behalf of Jean Loc Bruel Dear iz or Maden: ‘This better ix written to support the vin application of Juan Las Brumel eo that be may be accorded 0-1 extraordinary sizility thew stant to contizuc to expand opos hes already ouletanding muzneds in the worldwide frshion industry. Tem the Production Manager af Geag Kade] Studice, and have warked with such cliente as Vogue Italia, Numéro, dateevinw, Vogue Garinatty, InStyle) ancl Allure ran Loe Brone) hee boone increasingly well coon in our field as someone whe wil’ tofliihly neanage and direct fesdion thodels for cients, photographers, ete. Mr. Jenn Loc Eero} has a intined eye to eelont the most appropeivic models to be used in on advertising campaign, and subsequently has the ability tn manage all stages of the eneiplar process of producing tbe tight prodel foe a besuriful models. As a aqd ot}er cruatre job. Therefore, the quailty of bis work ts (ncrlble as he (sable to find the result, he ia fest becoming one of the professionals of choice for the fashion § inciuertries. 7a Tay opinion, Jean Lae Bronal, is ceayly ap imtividual of extraordinary abili in the fiebd of art, und the position be will aveurne ba the United States cearky requites an individual zy obdlity tn this Geld. Mir. Brunel fun feet internationally knew and recognized for bis umiqne taloat amd ewpertive, tha modals he finds regularly appearing tn the meet prestigious fushlon pubis around the world guch a9 Fle Maganinr, Cosmopolitun, Macy's, Nurcstrom. Me. 6 eee major cdSents lave secured bim « poeiticn as ene of the leading dinectors ind talest coordingtors worklng taday. [tis aleo toy opinion that the sesponmbitities and dutics of an international art director, who colishorates with the mat distinguished maguanes and advestising clients, require an tnctidual of extraordinary abétity and accompiishovenis such as Mr. Jeub Luc Brueel, gente an 0-1 vento work in the United fates, Jean Le Boel nl anne tein bin phere talent to the Arearionn muriet. Please do cot heslieis to comart ne with any quesrane. HOUSE_OVERSIGHT_011993

montage Mat 8T LAC RAST) @4ne, ONT REG. Qo TEL $6 fi tr FAR. oo ust Vermont Service Center 95 Lower Walden Strevi %, ATbous, VT 054 RE: 0+) Non-luwnigrant Visa Petition on behalf of Jean Luc Brundd Dear Zit or Madam: ney usage’ tae Conon ad Ty Froees of Moning Mixicfull Nave pam Lapel of ste haere end | am constantly in contact with professiohals al! A few at my clients include Ele Magexine, Simons, Pr Hwee Laura Shop, Ogily's, The Bay Stores......aad ap on. As guch, i quatified to comment on Mr. Jean Luc Brunel's carver as en art director of extraordinar: ability cheowe to atitter Mr, sing wel cxoanking coowetioes aranel Mr. oo is also an cheolute expert at furnishing his chenls with exactly the image of thele deals. My person! appreciation of Mr. Branel aules 4 amey for mr to i parva his scclamstians, Fram my mendpolet, they are certainly well confinmed. According, Mr Broncl to fa a position te commend sizable compenzation for his work as compares to Dir. Brunel's tation as a formidable artiet with a persouable demeanor precedes him. He is constantly researching and developing atismalatinaly new consepts for hie clients and f heve eoune to rely og and trast him and bis ability. Over the course of his celebrated career, Jean Luc Brujel bas distinguished bimeelf as onc of the leading fashion art directors in the Mr. Jeans Lue Brunel enjoys an extracrdiaer relationship to the aesthetic. This manifests teelf through the beautiful work he creates, tine efter Hise. Therefore. Jean Lac Brune! is clearly ons of the most talented Sree Ie ie nea 5 book forward to seeing more: of professionals his work in the future | | NOE Nadia Canova = ang? HOUSE_OVERSIGHT_011994

NebiedoS ROOM Sepiember 17. 2014 | USE Vennend Sarno Certer 73 Lower Welden Sirast &. Abane, VT 05479-0001 RE: 6-1 Nanamigrant Vaca Pettien on behalf of goan Luc Grmel eer Se or Maden: twould Hew te eatend my full end unqualified support for the axtracrdinary ebiiky O-1 vise petilien aubintiied by Mr Jean Lue Brunel Aa ihe Sensor Talent Producer fee Neordalvorn, Jam qualded te esy thet Mr Jean Luc Brunel fe on art deecic: ard talent coordinator of Ihe highest calbar whose technica’ excellence end crealive vision have $Red him te the top of hie profession Throughout Mr Jean Luc Brunefe distinguished careo, be hee received a hight, Impressive tet of crofesionst hanes end echiovements In the past few year, hr Bronel has atcuted bamutiiid models that have sppcared Ine fied of acclanmed projeci= in aome of fhe moet eminent publications in the world, which serves as © testament to his tant i 10 achieve the strongest rewulte from the mont carshiily devetaped crealive'concepts and dees. Bis his very unique abilty to conmnunicals, wa carciid analysis, the intenca: sreative mmqenge of ns cdants. & is cleor that MW Jeon Luc Grune is talented far Beyond the average levels for this rousiry by ihe siunning meri with witell ms work 3 condensed. indeed, fe has worked with some of Pre beat-lncen refgiiers, faaiion houses, and magazines hn ime world Wt ic: eBhout @ doJbi that | place Ain fh the canks 0° He very Dect in his profession | { can confidenily wattly thet Mr. Jesn Luc Grunete reputation nas achieved inamational stature. He hee reached o level where industry lenders now Geachbe hin oe 6 “ater. dean Luc Grunal’s extraordinary career # al & point where there 6 2 turning beck Serdar Tetant Producer ordi “goof arvice) tie eas Wis Fuga 4 eaeeee RA Va teint Sees bt pegs irpiaee HOUSE_OVERSIGHT_011995

Recommendaticn Letter 22/09/14 USCIS Vermont Service Center 75 Lower Welden Street St, Albans, VT 05479-0001 RE: 0-1 Non-immigrant Viea Petition on behalf of Jean Luc Brunei It is ax extreme picasure to write 6 letter of recommendation for Mr. Jean Luc Brunel. f provide thie recommendation based on my knowledgr and nce in the field of modeling, due to my ecatablished reputation and work in the field as the Viadimir Yudashkin, director of 1 Mother Agency. Kiev, Ukraine I have known Jean Luc Brunel professionally for several: yeare through our work together and, in my opinion, he ie an extremely talented individual] with superb professional reputation. He is an lextraordinarily able coordinator who atrives for and attains a level of merit in his work that only a few of his contemporaries meet. He haz the ability to recognize the creative vision of his client within the time and budget through his careful and thoughtful choice of model casting combined with his meticulous ability in the eld. Jean Luc Brune! ip a true find in our industry. | There are plenty of art directors out there, but none with the depth and quality that Mr. Brunel posseseca. He is unlike anyone in this industry, and I expect to see him continue to find great models in hia successful career. Someone overflowing with talent as Jean Luc Brunel should be given every opportunity to work in the United States, where he will have the proper venurs to showcase his extraordinary talents. Please do not hesitate te contact me should you have ‘any questions regarding this matter. Lice you for your time and -ednsideration. Sincerely, HOUSE_OVERSIGHT_011996

FIGQ/O °S) SECREE OP et eg £38017 RE Mytethey rr 9 bia CURA Rema LEP A Wt hunter GUITIG4 'S. of OPO Gt) Gt afee white fF) ey June 1? ame + * pony et | Department 6! Homelarid Security United States Cithemship and tnmigratian Services Vermont Service Center 30 Houghton Streat Saint Albans, ¥T 05476 Pd O08 | Sd o-!} Fattoordinary Abily a1 on Art Director ond Talent Coordinate! on betial of fean-iue Didier Hecr!-Rene dune Bish he oops. Aly 1S with fos tial PF tant ot ar ras lie Sone fislitior TE bereh Ge or art Director rind feuent Cascais 6 Untied Cover 43 9 Soden! oGerdiealet Vr. Fume’) bocce Gar ard pau be recs er He doce Coreg the mode, 45068 crraee fe Oued Sow OCheved 2 Burnell nos Grocers Gent MONON? -Uteus How Model troughs! it Conpe Torsly Tuingion, tig ea Ue urea Dy \F Gunret, hat peranifiet oaPected Deaety. cenasearning (ot tien’) Magnercus Beige 1967, TUANgION 4) wel Gh Onetner mode moratantod by Mr Brioe) feaowd Camppel baname one Cc” ihe few Spernadies ys monaged to te a ear fronstin Need) Me fea te orl. Of "he 1780's th ihe reddeet wewple ty of tha Myhoaine§ ie ae Teagan tee eter ceva fl on O fei co a. Soa) Freier Bavey See" Create Tufeogton hee oh Pra] di : ovine ot huncrecs af fosnion magaenes quch co Cceticcadten Wo Vague sn Fiteae Ge soa7egr Mare Clare. homer 1 itqure gma ewer (re AAcepant er Me Grune tem Gyo epee ferd fre ertameey pol as apres of supernova cr gr #amhel Hunter Gagren Slone, Mociga Seuecl] Ewha San ocg Chrsire lemons. ‘ome wore 07 roceeded ' becoroe tone of The feat) Pec tagriapred itera cover sreaedt in Th wed, comeor ng ocr Pago OF Mop Tie Chow! wide Fa Dorey) are errs AN oO te! of @h ep iotgn 40 Nyly kee wate celia why sie qarters and cetguch QUE MG JOOd ack Foe ment ane] fiers lero e deo) mony toy ple in ine keetren ona enfengomen feki "Gqueyacd Thyl Wr Ase Toeclion os eer axdusee ager! ona reorenn a +3 See 823 MOM [hor Greeting WEDere oiling an fr ear inne bare. Comronans 9 “32° * @renhy Gea Ira cp ponety "o hee to God tan eta fet to leseser in ihe Ureled hs ae +. at me al eA aparc F Sage G6 raat Mgkale (> Conk,” ave let ive Gry Gumhoor thrice ey ek pm “wr, ME i A Arete . 5 ° | Oren;tor — HOUSE_OVERSIGHT_011997

APUPDEL GLEN UC Cal ROY HEM ALAR DS VOSSbR 1 20) 48 ARR ee fel. COPS 9 Te Pa: OE ap sera new exalbwerd, ad: MODELWERK Homburg 6 July. 2014 Bepotment of Homeland Security United States Citzenship and Immigration Services Vermont Service Certer 30 Houghion Sireer Son! Albans, Vt 05478 Re: O-1 Extraordinary Absily as ar Ar Director ond Talent © o9odinater on bahatf of Joar-Luc Didier ~enn-Rene Brunei | To Whom ‘tt Atay Concern As o President of Mocebverk. this letler ¢ submitted in: support of faC2 Models Miami. LLC. on behalf of Mr Jean Luc Brunel to work as ar art Directos and falent Coordinator. Mi. Brunel aids an international rmputation a@s a valble. shotegi networker who 6 able ‘o cullivale expert relatiorshen management! skills 7 order io conduct business in a global ervronmes" and crocer tucrative deals. Mr. Brunet nas a long history # marketing and advertiong mapor fashion carnpoigns. Inraughout m: twenty-five year careerjin tne foirecn business, Mr. Brune! bas developed worcwide, exclusive lnodeling ‘tnd cosmetic carmipadgns. Some of these major cosmetic campo'gns inch-de Bio Therm with supermodel Eile McPherson, PHAS wih kebecca Korwr. Chiition Dior with Chibting Semonnovikaya, Margret Astor with Morica Selucci. Chanel walh Patios Vor Mckenneim, Ange Perlume wrth Thery Mugler, and Cocharel Perlume wilt: Aisa Ballestro. Mr. une! has ase developed maic: fashion cormocan: and nts developed compaigns and eguclusive Ccociwacts wih tome of the word's toc lasbens aggre fuch as HOUSE_OVERSIGHT_011998

Y¥ve1 Sow’ Lowen! Chonel Christan Dior, Gucci Jacobs. ~ in adiditen fo Mr. Jean lve brumel’s extensive butiness Qgolfications, fis CoVeer OS ON individual with artihe vieion and cregive talgnts has helped him find top fasnion models to resretent in the Uniled Sto! Should you have any questions abou! Mr Jear We Bung quallicotoris feel tee to contact me. om 1 "% i # ve! i - Claud: Middle». 14. ¢ President” ‘8% <9 23 100 Modelwerk Modcligentur Gimbll HOUSE_OVERSIGHT_011999

MOOTLY Saem- Gra Re; O-1 Exroordinary Ability a3 on Art Drector ond Tatant Cooydinator on behalf of lean-Luc Dicker Har-Rane Grune! To Whom 4 Moy Concern: AS @ Preddent of Natale Model Monogement. ths letter b submitted in wppert of AC? Models Migr, uC. on Denhait of h¥. Jecn Luc Brew tc work asp an Ast Director and latent Coordinator. i Brunel hokks on mtarnatonol putation at a viiblg. rrotegic nelworker who fs aie fo culllvate expert resotionerip management skis ender to Conthuct butines © o globol envronment and broker luanive eds. Mr. Brunet hos a tong Nistory in marketing ond cdverting major feshion conpdigns. Trroughavt hh iwendy-dve year career in the fashion busts Mr Brunei hos developed worldwide. exclusive ing ond coametic compoigns. Some of thew mojoxr counesfic co 6 nchiche: fio Thann with supernocial Ge MePnenor. PHAS wih Rebecca Gorrgn. Ontiian Gior wih Christina Semonnovikayo. Margret Astor witti Monica Balver, Chana wilt Patties Von Mictanhaim, Angel Ferlume with Thiesty Mugler, ond Cochoral Pelume wih Alda Bollesta. Mr. Brune hos ako developed majo faihion campaigns and has davelopad campaigns and euchaive contrech with some of the word's top loshion Gesignes puch os 24 “Agenturs NATAL @* yrwtusen elo 21/2 Wigan iv 1611 bamiss Ter: oRPC PR 216 tase, 2B Fd) 7418, © per netelie@apote . saew rater eh com Beg °e LWWSO0DI held, A'S PARLCSS BANKA, tic: PARALTE)! sorts L3G PAR AE) SONG BiG) 5 ' HOUSE_OVERSIGHT_012000

Career Gs on individucl with artic vision and creotive icient} has haiped im Geicftion fo Mr. scorn Luc Grumei'’s extensive Dudnen sont an el his hitn find ten tosthion models tp represent in the Ursied States. | Should you have ony quesfiors obout Mr, Jean Luc Brunel quatifications lee! ee fo cantoc? me. | Exk Makan HOUSE_OVERSIGHT_012001

sci8 Vermont Service Center I 95 Lower Welden Street St. Albans, VT oga79-0001 RE: 0-1 Noo-immigront View Petiétion on behelf of Jean lar Didier Henrl-Rene Erne! 1 write this letter in strong support of Mr. Jean Lue Brunel's applicat:on for 4 nen-immigrant viaa ta this country, I qm currently Amministratore Unico ts Studio Fp. I have been asked to review the professional credentials of Ma. Brunel, and it is my professional opinion that Ma. Brunel te an At Firector and Tatent Coordinator of extraordinary ability who ravtks amang the amail percentage of farvign peaple at ver} top of his fleld. I have geen first-hand Mr. Jean lam’s special expertise im the field, incliding casting. production, coordination, and art direction far ahoots. Mr. Brune! ls considered by those im our industry te be'an extraordinary creative director talent, particularly for the fashion and related Industries. Tt pry personal dealings with Mr. Jean Loe Srincl, [ found him to be thoroughly professional and capable of being, utlliged in connection with a wide range of creative subject matter om any mmignnient. He has the intuitive ability to provide just whet's needed in connection wih any particular creative proce: and possesses excellemt tic management and operational skills that pone from bis years of experience. Many peop!e do ot understand that behind every scecessful advertising campaign and fashion shoot there are creative men and women who are making sure that the business operates efficiently by peordinating different tasks between models, photographers, amd managing creetive trame | can honestly say thal Mr. Brune! aontinuslly proves himeelf as an extraordinary talent to his field. i | offer an unmitigated endorsement for Mr. dean Lue Brunet regarding his vina application ss a person of extraordinary ability. Thpre ie no doubt in my mind that his popularity and ability in the ficid will only cantinue to Presper in years to come = 1 HOUSE_OVERSIGHT_012002

9716/14 V3GR Vermont Bence Conver 73 Lawer Welden Stree: &. Abans, VF 5479-000) 1 BH: @.1 Non-doemagrent Vian Frirteen an bea! of Jean Lue Brun) : h Deer Ge of Modam. | t enw Que Wier m strong support af Mr Jean Luc Brenela applicofcs 7 a mon as tp Chee country, | am currently working os an Ageet et Two Munagerme im Loe Angeles Based upen my standing im the faid of tic fashion industry | am equens: cabed tc evaluate the credenualy of olber profreucnals om the field | hove been Ghee be review the prafemecnal credentials of Mir. Jean lag Beane! It we oy peefedcicnel opmien. based upon my persenel end profeaminonal kncwieige of Mr. Brincis talents, thar tr Bravel u an art director of extrvordinary abihty eho ranks ameng the mal pArcentar? of foreign preécesinna!s 31 wry top of hus bel. 3 greatly: admire Joan tue Brunet and ted 0 oa picasum f work win etic ao inlepied Petia. Judang ty the high promie guecraa of she compearues with whieh he regulate @roviea, chearty | am mot the nly om eho apprecigtes hie talant. Hie models! hese appeal ad to bay ol the waeNe's saat pujzutar publicetiann, reaching bteraly mélioce 4! edinvers He ts perticulerk: fumous for brs eerk i jechicn, advertining and educce! sorkl He contrutiog to major chen, mich s¢ Galvle Kien, Genel, Christian Dot have aecured him @ godtien as one of the leedmg ict iastuon art derectore working tddsy. Jean Lu; Brunet is the consummate profeseqanel when tf comes bo the at of faahion god his work efi: fiapieyed in worlds most eitte miagmemern A true arte. he mm cummiiied ta the @ntielection of the chant on every gocasion. Although Mr Grune) covnmeneds the Regret @aeapeentem for hee werk. be ta well worth Lhe cost. Mr Jean Lut Grand Oo uoquesisunetty an cviividual of extnsondhnary trent, enerpy, intereadional echwewsreent and ockraviedemcnt. hhould you Rees any questions iegerdhiag My. fewnels extracrdmars atnlity, plemee (ccl free to contact me Thenk you for your sthenuen ang conmderanen. HOUSE_OVERSIGHT_012003

GREGKADELSTUDIOS 0) Erosdetey init Geor now pork 10093 + 313.516 fora dni NIRA STUGIOE com SE: 0-1 Nen-feiigratt Vies Petition on behalf of Jean Loc Brunel Dow Sr or Madam: “This Detine fe written to support the visa spolicetscn of Jeca Los Brumet so that he may be accorded 01 extmartingry abllty vw steucs tw comtinuc to expaed gpop hee already outetanding axome ie the workdelde fishies industry. Terms the Production Manager at Greg Kedel xpdiog, and heve worked with auch eMlents as Vogue Matic, Numéro, Interview, Vogue Germany, InStyle) and Allure dem Loe Brunel hes beanme increasingly wall encom in our field as ecneone who wil imfallthty ges selees a eet owotoptiate med ln forbs wae aan sdvertbaing puegnlgn and aueeceroenthy jon the onetendlog ability ta menage all stages of the ecemplmn process of producing the right model frr a job. Therefore, the quality of bts work ts incrolzble ag he is abla to fled the bewutiful models, Aaa rae br fe onion ce Ue ofeach Gta etae! rpm eoiaber ee In my opinion, Jeon Lane Brunel, is ceutty an individual of extzaardioary wbility ia the field of at, and the position be will assume in the United States dearly requcres an individual of extraontinary ability in this Geld. Mr. Brome! busy heen bnternetionslly lon and recognized for his unique tallest and who collshorates vith the atest distinguiched magiones end advertiaing cliemis, raquive an individual of extraordinary ab@ity and accamphishnoenia such we Mr. Jean Lue Bruse, ioewly, Production Manayer HOUSE_OVERSIGHT_012004

montage | Mat ST LAURENT #48, MONTRILG, GH TEL, 516 De el 1k 3) e ee ede ] ust Yeemont Service Cente: 95 Lower Walden Sirees | Wulieatia: Laciva Saupe Onivee ‘The Bay Stores...and oo on. Ac uel, I am qualified to comment on Sir. Jenn Lac Brunel's career as en art director of extraordinar: ability its Rot only because of his acclamations or his tmpressive body df work vag teshion perenne Id HaMeliny seeceies Groee We we Mr. Brumaf's reputation as a forinklatle artiet with a personable " prncedes iia. He is constantly researching and stimujatingly new conaepts for his cliente and § have come to rely on and trim and his ability, Over the course of his celebrated career. Jenn Luc Brunel bes bimeetf os onr of the leading fashion art directors in the professionals working in the world today. 1 Sook forward to sselag mare of hie work tn the future. | | Yours, | Mirae — reise Nadia Canova meutge 7 HOUSE_OVERSIGHT_012005

Neves TROM RE: 6-1 Nensmmigrant Vaz Pittinn on behall of saan Luc Bnunel Deen Sir or Madertr fwould like to extend vy full and unqualiied support for the extractdinary abiity O-1 vies petition submited? by M:. Jeet Lue Brunel As ithe Gere [slernt Producer fee Nordsyom, } em queified to epy het Mr Jean Luc Grunel le ar ert Grotto: and tren! coordinator of Bye highes! cattber whose technics! excellance and creative vision have Wiad ham to the top co’ his profession. Throughott Bir Jean tisc Brunafe distinguished career, he nam receed a hight impressive Get of profesional honors and echevemumris. In Me pes! few years, fe Brana’ tia @touled beewiifid models thet have appeared ino lie€ of acclaimed project: in apie of the moet eminent publications in the world, which serves an & tottament to hie 1 am & coneion! witness to the crestive end operaiional shils of many creative direction pectin, ee a ee ee ee Ht fs therefore my ploseure to recognize tue rememiaible talent and echirversnts of Mr. Jegn Luo Brunel, He manages to io-atichrve dhe wvorggend ret from the mast caredully developed craalive concepts arnt down. Bie hls very uroque abiity bo conmmunicele, via carefud analysis, the intense! ctostive massage of his cients. & ic clear that Mr. Jeun Luc Brunet ip talented far beyond te average levels tor thie Fioustry by the sunning mort with whch hie work & considered. indeed, he has worked with some of *e best-known reigiiers. festion houses. sad magezines hh he wortd Mle ethout & doubi thet # place Min fh the ranks oF he very beet in hie profasnior | | can confidently wetify thet Wr. Jesn Luc Grunete repwiadon nas achved intamgtional stature. He hee reached 2 lieve! where induely leaders now deectibe han 20 6 “ater”. staan 11s: Gininel’s extraordinary career it at a point where there lb tO turnit!g Deck Serdar Tolan Produce: Nordstram ' Samed strane) dr | OMEN Mecleigaes eet Sortie AN QTE 1 hr a fal phar Soe HOUSE_OVERSIGHT_012006

Recommendation Letter 2a j09/ 14 USCcis Vermont Service Center 73 Lower Weiden Street &t. Albans, VT 05479-0001 RE: O-1 Non-immigrant Visa Petition on behalf of Jean Luc Brunel Dear Sir or Madam: It in. an extreme pleasure to write a letter of recommendation for Mr. Jean Lac Brunel. I provide this recommendation based on my knowledgr and experience in the field of modeling, due to my established reputation and work in the field as the Vladimir Yudashkin, director of 1 Mother Agency. Kiev, Ukraine I have known Jean Luc Brunel professionally for several, yeare through our work together and, an my opinion, he is an extremely talented individual with superb professional reputation. He is anjiextraordinarily able coordinator who atrives for and attains a level of merit in his work that only a few of hia contemporaries meet. He has the ability to recognize the creative vision of his client within the tinic and budget through hig careful and thoughtful choice of model casting combined with his meticulous ability in the field. Jean Luc Brunel ib a true find in our industry. There are plenty of art directors out there. but none with the depth end quality that Mr. Brunei possesses. He is unlike anyonc in this industry, and I expect to see him continue to find great models in hie successful career. Someone overflowing with talent as Jean Luc Brunel should be given every opportunity to work in the United States, where he will have the proper venues (c showcase his extraordinary talents. Please do not hesitate to contact me should veu have any queations regarding this matter. you fer vuur time and consideration. ' HOUSE_OVERSIGHT_012007

FIGQ/O | "MN SEEMES OF OTEGeG MOET th OE GATE. Ue Se a ATMA SO ALENE A Warns thapber 6417101 - me dune 17, 2014 52 Aer Cee oy : fn (er SAAT Oe | Lob Homeland Security United States Citeenship and immigration Services Verment Service Center 30 Houghton Street Sait Albans, ¥T 0476 Rear Ses Be O-l Fatoonfany Abily os an And Deecter and Talent Cocrdingio! on behol of iean-ioe Dike: Herri-fene dune raisn fhe cope ely TO ente fres mtiar i memo at ve Jean lor Sune Hptihion fo work oe) at Grector and foiact Coscciestor 6 the Linde Ste Aa a2 tent coorde-algn Vi. foumel's puccen Con ord (ou be means? wt the qccenfia Cordes he men ose forces be Gu hed Pare po hewe!, AY Byre| tos Osteo ed and represented various 06° nodeti Hroughou! i Colwe: Tovsty Tudnglon. whe wus Gsccrered Dy Mr Sune hoy pananties Unaffected peaiy. eoresie tig Cohn Kier | Mipgrericeas wee 1987, Tutingion 6s wel 03 Orecthar Mods cocresared By AY Brood hoon! onpiel. ne@come ene c? Mg foe BypErodes wt maraged f man an easy bons Poh He hot somal Cf thy 1980's °S the vetoed fmpie *y of the eigen g deqade Througiay) her extends coreer Og oO retail oP Ay Bagi) hortroc- Soviy Gye” Ciwty Tureigtars fem gineseet Wie (anes of numdrec: gf fostwar Tiogctma; Geer so Licemoccitor ¥, Vegun Srane fitven Fle Baroor “are Clive. horper 1. bequre. and ewes mre Mogosct Mr, Grune! tes deo lGuhcteed He ether, sich) cores ot a 4 tues cre Pepin Honter Sargon Store, Morice Fehucci Gitela woven seg Cheating ovikeys. ‘ese womne: of proceeded (¢ Dec uiie Syme ot the Mop PPotograpren: imtert cove: moaels =: teh WEFT. Comer On TNGuoriG! OF PeOgole Covers aitdewe ne spcr mony weer Al 3 tent! of hh eptO8On TG Nahy Wiles ovege oehworke woo culyctes amg censuct: DUWIS 18 OOS Ge fcr rmract and bobo Kerctins Jeay ergy ge paves 6 le Senco ota erenoo tie "eel recvetsd Mat wr ory forieiiore a) ler aagusee aga! ong Morar 'o" ve “@ °O.3 [OG fore Niort Groening @epeneree outing wel: Ae deo Le brunet, cosruno tag a9 “Se Se Svenhp org Be coieety rime Pe fore Ig Seg tan mee Mgt) be regreter) @ le Uotad Paepgse dt ict Mayghale bio Confar! re | wo) oes ee hao Sul at tly al irose a 7] | Orectcr == HOUSE_OVERSIGHT_012008

MODELWE RK SMPDE. ACEI TU58 CrmbaE HOTHE SAT ICM AL SSPE (Nak ARERR: ig) #Ote 7 Te NW FARK BDA0.40-44 791 , ew omdelwed, oy Harnburg 6 duty. 214 Bepartment of Homeland Security United Stotas Cilizanship and Immigration Services Vermont Service Center 30 Houghton Street Sonn! Albans, VT 05478 Re: O-1 Extraordinary Ability as ar Ar Director and ‘alert inna on behelf of Jear-Luc Didier Henri-Rene Brunel To Whom ‘ft A4ay Concern 43 G President of Mocetwerk, this letter 6 suomitied in supper ef fC? Models Miami, LLC, or behalf of Mr. Jear: iis Brunel to work as ar Art Director ond tolent Cocrainatc:. Mr. Brunel nelds on inte-nofional reputation as a velble. stalegic neiworser who 4 able 'o cultivate expert relatiorsha managemant skis in order to conduc! Ovsness in a global ervronmen’ and ofacer icrative deals. Mr. Srunel hos a long Aitory «4 morerng ¢ ie adveriong mexor fashion campaigns. Throughout nis twenty-five yeor career|in the foson business. Mr. Grune! has developed wocdwide, exclusive modeling and cosmetic campagns. Some of these maicr cosmetic campaigns include. Ho Then with supermode! tile Mc@hersor, PHAS wilh Rebecca Korn. Chvifiaon Dion wiih Chuthing Semonnovikaya, Margret Astor with Monica Bebucci, Chonel with Patioa Vor Rickenneim. Ange Ferfuine with Thery Mugler. ond Cochare! "ertume wilh Aida Ballestro. Mr. Brune has also developed major fashion campaigns ang has Geveicped compaigns ard eaxcluswe contracts with come ol the veorls’s 1923 lashes dedignears gjoch as HOUSE_OVERSIGHT_012009

I Yver Soin’ towel! Chenel Caristian Cicer, Gucc) *rade. and Mare JQcobys. in additon fo Mr. Jean Lue Brunel's extarsive busness Qadolifications, ht Coraer os on indmduol with artishe vision ang creative taignis has helped him find top fasnion modek ta rep'esen! In fhe Urated Sto! Should you have ony questions obou’ Mr Jear Luc Baené! qualilicchons feel free to contact me. Lint wy pts 1 fv’ Claudt- Midelo = ; Presi’? ! 28S) 73 409 Modelwerk Medelagentur Osuisl HOUSE_OVERSIGHT_012010

MODELY 40th" Oea Aly & Zita Oeporirent of Hommand Security United Shotes CRizarship onc invnignation Servines ¥ernort Service Center | 20 Houghton Stree" Saint Albans Vi 05478 Re: O-T Edfroorcinary Abily o9 an Ait Dvecior and Tatant Ccofanator on behett of Jean-Luc Cicer Har-Rene Brunel To Whon tt May Concern: AS a President of Natale Model Management. tha letier # svomitted In suppart of MC2 Model Morv. LC or benoit of AW. Jem Lic Bnew tc west at on Art Director and Tarent Coordinator. My. Sune hokh of intemochonol neputation @ a vitbig. srategic nelworket whos & able fo cullvate expert reictionsrip management skits in order fo Congct buriness ino globo! envtonmen! ond oroker lucrative decks, Mr Grune! hos o long for in marketing and odverting majo feshlon carnpaigns. Thrcughawi hh heenhelive yeor career In fhe fashion Duiineis, Mw. Brunel has devcioped woddwide. exciiive modeling and cosmetic compoigns. Some of thee major cosmetic campoiges Include: fia Therm wiih supermodel Ele McPhernon, PHAS with Rebecco Romgn Ctirfan Dlor with Chifinn Semonnovskaya, Margret Astor with Monica Galveet, Chanat wilh Patricia Von Riezenheim, Angel Pelume with They Auger, and Caochoral Perkene wih Aldo Gollesic. Mr. Brune! hes oisa aoe. majo foahion compaigns and has daveloped campaigns and AN aE te oe ee ee et ee Yvet Soint towent. Chonel Chiisiion Dier, Guect Prada. [and Marc A “kgenidirn MATAL I Gartrusire ole 57/2. Saga (V-1011 -rteind Wale: 2 091 9) 2184 tree 9 APS FO) 000. o parts Hetelegtapote by, aww nalplencuals cunt Rag fir (WS000) 22e24!, A> PARES BANKA, cocks PARLY2) ont: iv d6 FARR ib 2000 410° 9 HOUSE_OVERSIGHT_012011

i im oddehon fo Mv. yeon luc Brune’ extemive busnes gutdificatian:. his Ooreer as on individucs with oartktic vigon and creative hés hated him find fen foxhion model: 19 raresent rt the tiviec Slates. Shaadd you have any quesiien: abou! Mr. Jean Luc Brune? feel fee ta Contec! ms. Gk Mesam HOUSE_OVERSIGHT_012012

Vermont Service Center Attn: Premium Processing Unit 30 Houghton Street 5t. Albans, Vermont 06478-2359 Facsimile Transmission To LUIS FONT Fax Number: 19642414272 Number of pages including cover: Date: September 6, 2014 From: Vermont Serwce Center — Premium Processing Unit Fax Number: 802-266-1778 Email: -PREMIUM PR Hi Phone: 1-865-315-5718 Receipt Number: Aflached you will find a copy of our gecision conceming your case The orginal decrsion will follow via mail If eligible to appeal our decision appeal forms wil be included. “Important "Important *imporant™"Important"* If responding to a Request for Evidence or Intent to Deny, ensure you include a copy of ihe decision immediately following your covet page and indicate the lotal number of pages included with your response Please include the case receipt number (eg EACO1 000 12345) wih all comespondence Ensure when responding te this requesl that you fax your response to our NEW FAX NUMBER - 802-288-1778 if you wish to mail a response. it must be sent to the VSC Premium Processing Unit at 30 Houghton Street, St Albans, VT 06478-2399 Do not send your 7esponse to the 75 Lower Weilden Street acidress, as thal will cause delays and will not restarl (he premium processing clock until the response is identified as 4 premium processing case Title 8 CFR Section 103 2(b)}(11} Submission of evidence m response to a Service requesi stales All evidence submited in response to a Service reques| must be submitted at one time The submission of only some of the requested evidence will be considered a request for a decision based on the record This cammuncabon ss ntended [tr the sole use of the individual to whom is addiessed and may contam infanmaten lhatis prvileged coniidantal and exempt fram disclosure under appicabe aw =f the reader of ths communeation js fol (he wlended tecpient of the employee of agent lor delivering the communmalon fo the intended recent you are hereby notdied thal any dssemmalon detibulpn or copying of thé communmation may be sinctty piohbiled = If you tecewed this communeaton in enor please nolfy ihe sender unmedntely by telephone and retum the communitaton st lhe sddtess above via Unied Sales Postel Senme Thank you WYAW.USCIS.qoV HOUSE_OVERSIGHT_012013

US Department of Homeland Security Notice of Acton U5 Citizenship and Immigration Services Page I of 4 Applicant/Petltioner A # Application Petition Feinuon For A Norummierant Worker (lorm 1] 29) Notice Date Response dur by August 46. 2014 November 21, 2014 MC2 MODELS MIAMI LLC IU TONT : - Ee . 4440 HOLLYWOOD BIA DSTE 4t2 LAZIO HOLLYWOOD fi 33021 Apphcant/ Petioner MC? MODELS MIAMI LLC Beneficiary BKUNEL JEAN LUC Receipt Number EAC 422550803 (11 49) FREMIUM FROCESSING IMPORTANT THIS NOTICE CONTAINS YOUR UNIQUE NUMBER AND MLIST BE SUBMITTED IN THE ORIGINAL WITH THE REQUEST ED EVIDENCE 1 US Crzenshup and Immigrabon Services (USCIS) requires additional evidence to process your form Please provide the evidence lated on the attached pagets) For Form 1-129 onb, if yoa are requesting consulate embassy nolwicauen, provide the requested evidence m duplicate 2 Your respense must be recered m this office on or before November 2] 2014 Please neve the required deadime for providing a response to this Requeat for Evidence The deadime reflects the maamum perted for responding to ths RFE However, amce many ummigration benefits are lone sensitive, you are encowsaged to respond to this request a4 earky as possible but no later than the date provided on the request You will not be granted an extension of tume te submit the requested evidence 3 You most submit all requested evidence at the same time If you submat andy aome of the requested evudence, USCIS will consider il a request for a decision on the record [RK CFR 103 WbK TN] 4 You wall be notified separately about any other appheations or petitions you have filed 8 From the date this office receives your resubmission, a mimimum of 14 days will be required te process your form [Lf you have net heard trom USCES within 40 days, you may contact this office at (866) 318-5718 6 Mail this netice and your response fo VSC Frenuum: Procesurie Vermoni Service Center 30 Houghton Street St Albans VI 05478-2399 ¥3¢- premium processing@-dhs pay HOUSE_OVERSIGHT_012014

US Department of Homeland Secunty Nobee of Artion U§ Citizenship and Immigration Services Page 2 of 4 EACH 225 R07 29) Fe ee __ Responses (ior Premium Processitiy cases only) may be laxed to (802) 288-1778 Include acapy al ths notsce Thee mail address may only be used for inquiries Do not send responses ta the e mail address 1-129 O- 1B Extranrdunarny Abihty in the Arts You MCZ Models Miaim LLC filed Form !-129 Pethon lor honmmigtant Worker seeking O-1E nonummuigrard classification lor Jean Luc Brunel as an Art Durectur / Talent Coordinator The 0-15 classiticauen apples to mdividiuals with extracrdimary ability an the arts The arxividval must have sustained navonal or internahonal acclaim His or her achievements must be in the held of expertise and show a record ol prominence in his or her held ic process your petition ami determine 1 the beneficiary 15 eligie adkhucnal mtormation 1s required 7 his request proviles suggested evidence that you may subnmut to satsty each requested item You may Subinit one some er all oi these dems Suimul none of the suppested jems and instead submut cther evidence to satshy the request Explain how the evidence in the record already establishes ehpilality Request a decision based on the record Note, however, thal you are responsible for providing evidence thal lest shows that you and ihe pares lo ifs petyon Dieel all requirements, Evidence must show that all parties were eligible for the requested benef when you filed Form 1129 General Requirements lar All O Nonimmigrant Petitions In peneral petitions seeking O nonuamigrant classli¢ation must include Copies of contracts A deseription ol the competition(s) event(s) or pertormance(s) and Al least one consullaor: To salisly these requirements you submutted Your letter in support cl the penuion and Peer letiers in support cl the beneheary trom Claudha Midojo and Alla Amantova Beneficiary $ Frevious 0-1 Status Petitions involving an extension ol status lor a beneticiary thal has previously been jsartecl O 1 nonmmugrant status may he piven delerenre however US Crazensmp and Immigration Services (USCIS) 15 authorized to question exlersion peutions when a subsianuel change wn cireumslances occurs when relevant larls change Irom one penuon to analher cr when ihe priot approval may have been based on pross USCE error You mndicate that the benenuary was previously granted O-1 nonimmigrant status with your Company Phe details of the beneliciary $ previous employment wilh your company are nol documented mn the insiani petinan A review ol lhe evidence subnutied indicates that ul the beneficiary's role wilhin your organizalion has remained unchanged (he previcus petition may have heen approved in error, as the bs! ol duties you provided do net appear te desenle a FUR UPFICE USE ONLY Form | 797 (8/03/90) ¥ HOUSE_OVERSIGHT_012015

US$ Deparooent of Homeland Secunty Notre of Action US Citizenship and Immigration Services Page 3 of 4 EAC 1422550803 (11 29} position in Ihe arts In adthtion no evidence has been sulmitied ta suppor your ¢laim thal the benehciary 1s an indradual who has extraaniinary ability in the arts that has been demonstrated ly sustained national or inlemnational acclaim You have documented the beneficiary s past success in the business of forming and operation modeling zgercies bul Uys evidence points to the benetiqary’s ahiity on the field of busmess net the arts Therelore you are asked to comply with the following Contracts Petriions seching © nommmigtant clasutication must include a copy ol 2 contract henveen the beneficiary and either the a peuoner or the employer {1a writlen contract choes nol exist you may submit a detailed summary of the terms al the ofal agreement between the heneliciary arxl enher the petruioner or the employer cn You ¢hd net submit any evidence for thr requirement You may stil submit evidence 10 satusty al Written contracts or the summery of the terms of an oral 2greement must specily the terms antl conditsons of the employment or sereices: They musi Specity the wage ollered and explain the terms anal conchtions under which the beneficiary will pertorm (hese services. and Detail any adinonal services provided Nature of the Event or Enpayeinent ‘You must provide an explanation of the competition event or peromance in which the beneticiary will participate An event means an activity such a§ a scleniutit project conlerente convention lecture semes academe year or engagement urine the requested valuliry period The descriphon you sulmutted 15 insutticient In your latter you hsi the duties al the prolfered postion as : Kesponsible lor overseeing the arisic aspects of the apery (select the imaprs placed on the models business cards end im them portichos) Coorthnate the pang ol models with photographers Direct the markelng ot madels to chents Travel around the world to discover new talent and to gr them with MC2 Motiess and Establish relahonstips with agencies around the world and nepoliate representation agreements The duties you descnbe appear 10 relate exclusivezy to the mamienance of butness cpetations of amolehng agency As previously ated ycu have documented the benchoary s past success in tarming and operating modeling agencies however thas evidence pomts fo the beneteiary 8 ability in the hekd ol business not the aris [tas not evident therelore thal ihe O 1B norarmmigrani classiication 13 appropriate 1 the insiani case Kegulahions detine (he “arts” as any held ol creative activity or endeavor such as but not hmied to line arts visual arts Culinary arts aral performing arty Allens engaged in the teld of aris include net only the principal creators endl periormers bul other essential persons surh as but nel hmuted to directors setiesigners hghtng designers sound designers choreographers chorealogiis conductors orchestators coaches amengers musical supervison costume FOR WERE US. ONLY Form | 797 (8/03/90) ¥ HOUSE_OVERSIGHT_012016

US Department of Homeland Security Notice of Action US Citizenship and Immigration Servii es Page 4 of 4 EACIA2eS50BU9 129) designers. makeup 2rusis theht masters, slape technicians, and animal trainers The dues you descnbe corresporal to business and management functions not to a position in the aris Belore adjuthcation of your peliuon can proceed this discrepancy must be resolved You may sull submit evidence to satisty tus requirement The description must include - Anexplanation ol the nature of Ihe events or activities, Beginning and ending dates of the events of activities, and A copy of any itinerary Ihat shows dates name(s) of ihe employer(s) amd jorauion of the event(s) You must establish that the protiered position qualities as a position in the arts as described above Any anc! all claims must he fully supported ly documentary evidence CON A FOR OFFICE USE USLY Form 1-797 (B/03/90) Y HOUSE_OVERSIGHT_012017

FONT LAW GROUP, P.A. 3440 Hollywood Boulevard, Suite 415 Hollywood, FL 3302) Tel, (954) 241-4271 Fax: (954) 241-4272 November 3, 2014 Director United States Citizenship& Immigration Services Vermont Service Center 75 Lower Welden Street Saint Albans, YT 04479 RE: NOTIFICATION OF WITHDRAWAL OF I-129 PETITION WITHOUT PREJUDICE BY PETITIONER EAC-14-225-50803 Petitioner: MC2 MODELS MIAMI LLC Beneficiary: JEAN LUC DIDIER HENRI RENE BRUNEI. Dear Sir/Madam: Please be advised that this office represents the above referenced petitioner and beneficiary in this immigration matter and a G-28 from our office is an file. THE PETITIONER, MC2 MODELS MIAMI LLC HEREBY NOTIFIES USCIS THAT IT WISHES TO WITHDRAW I-129 0-1 PETITION #EAC-14-225-508013. The petitioner requests withdrawal of this |-129 petition without prejudice. Please note this request for the record in the above referenced case. We respectfully request that you send us verification of this withdrawal pursuant to the regulations contained in 8 C.F.R. Sec. 103.2 (b) (15). Kindly send our office a written verification of this withdrawal located at: Font Law Group, PLA. 3440 Hollywood Boulevard, Suite 415 Hollywood, FL 33021 Thank you for your altention to this matter. HOUSE_OVERSIGHT_012018

—--- Original message —-—— From: Jeff Fuller Date: 11/12/2014 11:49 (GMT-05:00) To: Jean Lue Brunel Subject: RE: New York fean Lue, lam really sorry you feel so bad and { know it has been a mental and psychological frustration. As you know | chose to partner with you due to your reputation in the business for being a top scout and developing a couple world class agencies in the past. | knew what you could bring and | knew what | could bring and contribute and | thought it would be a great partnership. Clearly, | never expected to have the level of challenges we have had recruiting new models over the last several years. | could have never foreseen the problem of your friendship with Jeffrey Epstein turning into the situation it has where you are seen as guilty by association when you have never done anything or even been convicted ofacrime. Frankly, | don’t understand the necessity for Conchita Sarnoff or anyone else to continue to defame your name and MC? by asscciation. It is true that we constantly have to justify ourselves when recruiting new models. The industry is extremely competitive and as a parent myself if faced by the same information and having to make a tough decision between too agencies | would not pick MC2 if | saw the article online about you. You have to read closely to see there is not a charge against you but the implication is strong and of course now days everyone believes everything they read online even more than the traditional newspapers of the past. | know you are now feeling like a liability to MC2. But you personally are not a liability to MC2 but this published information online is a liability. We are not a large enough company, nor do we have the capacity to fight this on a global level. On a google search in America we have put enough information online to not have it popping up so blatantly but we have no controls over the rest of the world or the finances to control this situation and we are affected as every major model agency recruits it’s best models from all the various countries abroad. This has stunted our growth and our billing over the past 6 or 7 years. In fact, we do not even know who avoids us based on finding this information. | have been surprised how challenging it is for us to grow due to this problem. | have also had a tremendous amount of worries from our clients that we are vendors for that are large American corporations likes Kohls, JC Penney, Sears, Nordstrom, Target, Neiman Marcus, Macys, Saks, Belk, and so forth that require vendor agreements and for us to be considered an upstanding company. It really worries me as some of those companies have disassociated themselves from what EXHIBIT K HOUSE_OVERSIGHT_012019

they believe to be questionable companies. So far that has not been a problem but it could come up in the future. The fact that you are requested for so many scouting events in various countries and cannot promote yourself properly to promote MC2 in the press due this problem has it’s own sent of repercussions in terms of our global branding. In short, it has had a terrible effect on MC2 all around. | really urge you to solve this problem and get this removed from the internet so we can grow for the future. I’ve fought for MC2 and been extremely loyal but | must confess that | have even been feeling inadequate and questioning my ability as the leader of the organization. | can only attribute the fact that we have scraped by in the recession and barely survived in the past to your hard work, my hard work, and the tenacity of both of us combined. | can only imagine that if | am feeling inadequate and frustrated over a lack of growth of our company that you must feel even worse as you have had much greater success in your career and have operated at much higher standards in our industry in all areas from reputation, respect, admiration and monetary gains. | can even surmise you are probably feeling a level of depression and | have seen it in your highs and lows and when you have vaiced your frustration. While | know you well and recognize you don’t really go for the kind of advice | will offer; however, | think you should at least speak to someone neutral such as a therapist or a counselor to let your frustrations out and if you don’t feel better and are still feeling down or depressed to see a medical doctor for your condition. You are such a positive person | hate to see you fighting what you feel is a hopeless battle. It is not hopeless you just need find a way to get that information offline and begin to repair your reputation. In the end | am afraid the damages are a lot more than you realize but let’s keep fighting and moving forward as we have no choice. Thanks, Jeff Jeff Fuller President MC2 Model Management USA EXHIBIT K HOUSE_OVERSIGHT_012020

FROM: JACQUIE JOHNSON <JJONMNSON@ RRA-LAW.COM> DATE: SEPTEMBER 18, 2009 3:57:44 PM EDT TO: "[email protected]’” <TDAAL\@TKUDALANLAW. COM> Cc: "BRADLEY J. EDWARDS” <[email protected]> SUBJECT: EPSTEIN - DEPO OF JEAN LUC BRUHNEL We have confirmation for Mr. Bruhnel’s deposition on 11/3. We will commence at 10:00 a.m. if that is ok with you, Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeldt Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale, FL 33301 Telephone 954 315 7264 Fax 954 527 8663 [email protected] EXHIBIT L HOUSE_OVERSIGHT_012021

-—-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 this shall delay things. I'll >let Michael know. > >Sent from my iPhone >Tama Beth Kudman EXHIBIT M HOUSE_OVERSIGHT_012022

From: "Dr. Royce Jalazo" <[email protected]> To: [email protected] Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an outpatient individual psychotherapy session with me on 12/12/14. Thank you, Royce N. Jalazo, Psy.D. Licensed Psychologist Dynamic Behavioral Consulting a DBA of Dr. Royce Jalazo, P.A. 1975 E. Sunrise Blvd., Suite 532 Ft. Lauderdale, FL 33304 Direct (With Voicemail): 954-232-7092 Toll Free Fax: 888-236-6979 or 954-208-3400 E-mail: [email protected] Website: www.DynamicBeh.com EXHIBIT N HOUSE_OVERSIGHT_012023

CTient Progress ‘ informations! Notation » LDINAMI. Dynamic Bebaviaral Coasalting int” a Bt I TAY KOR AL. 1975 E. Searise Bivd, Sulte 532 Piychatherany ‘ tomakorit é ameatars (Bent: err Date: jaliz [4 MT WTHFRSASU Servlet: vidual Session () Family Session Tine a san. / pm AOS wm. f pum, “TET Pewinwess ic | AFFRCT, a ait ae Agernpate Ue especomsse 7 {Ll lee Ey Orarstize: = Binted / Restrisied f | J Stighety trtesuar | LY Urknown - {elegtunic v2<200} PSYCHOTROMIC MEDICKTION: fetuic and cick alia ao) CR Bdae we chords —— Was paler refered Aw pppoe craluatios oy arnderagned emilee prescried paychetreys bamaiveton by o py cid! but present!) non-complia? (1 ¥ CN Comment _. at fs pulled camrent taking psychacopic merchcabsont ETYUIB Tye | Dosage: Compliaat as presented? (JA CT YO NCarmes MOTIVATION FOR TREATMENT.CHANGE: ~ - TI teghty meat Rrasombly motcaint Porty mutivated Uaeived DISPOSIT PON: a a a —— TT Conteur Treatent 2} “Ferminalion af Freannem [_] Reter $a paychdairist other prowader “Rear [| Omer: | nip Oo nin nat xt UAT Dieprenorg 4 Aprtinng Morel . EXHIBIT O HOUSE_OVERSIGHT_012024

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@D. NH HOSPITALINR 31 oie 248 maha H Tsowsnuiauiouiog | MR. JEAN - LUC BRUNEL Prozac (20 Mg) Capsule * Take 1 Capsule Once Daily After Breakfast HOUSE_OVERSIGHT_012028

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http:/Avww.politico.com/blogs/under-the-radar/2014/12/court-filing-levels-sex-claims-at- alan-dershowitz-200495.html Woman who sued convicted billionaire over sex abuse levels claims at his friends By JOSH GERSTEIN | 12/31/14 6:38 PM EST A woman allegedly kept as a sex slave by politically-connected billionaire investor Jeffrey Epstein, who went to jail for having sex with underaged girls, is accusing several prominent friends of the financier of having taken part in the debauchery, according to a new court filing. The woman—referred to in court papers as Jane Doe #3— leveled the allegations Tuesday against Harvard Law School professor Alan Dershowitz and Britain’s Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel. Dershowitz flatly denied the claims about him Wednesday in an interview with POLITICO. “Tt’s totally, unequivocally and completely false,” the celebrated attorney said. A spokesman for Prince Andrew denied the allegations Friday, while a lawyer who handled related matters for Maxwell did not respond to an e-mail seeking comment. Representatives of Brunel's modeling firm also did not reply to e-mail messages. The accusations came in a long-running lawsuit charging federal prosecutors in Florida with violating a victims-rights law by failing to consult with Epstein’s victims before signing off on a plea deal. That pact ruled out any federal prosecution of the investor, who agreed to plead guilty to two state prostitution-related felony charges. Lawyers for the victims have described the arrangement as a sweetheart dea] the well-connected Epstein and his high-powered legal team achieved by putting pressure on prosecutors. Epstein served 13 months of an 18-month sentence on the two state charges before being released in 2009. He's now a registered sex offender. The new court filing, submitted by Florida lawyer Brad Edwards and former federal judge Paul Cassell in a federal court in West Palm Beach, Fla., asked that Jane Doe #3 and another woman be allowed to join the pending case over the victims’ rights claim. “Epstein. ..trafficked Jane Doe #3 for sexual purposes to many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3 to describe EXHIBIT R HOUSE_OVERSIGHT_012032

the events that she had with these men so that he could potentially blackmail] them,” the court filing said. “One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin Islands,” the legal pleading added. Dershowitz called the allegations “totally made up and totally fabricated from beginning to end.” He said he was not in the places described in the filing at the relevant times, with one exception: he did visit Epstein’s private island in the Caribbean on one occasion. “I was there with my family,” the renowned law professor said. Dershowitz said in a follow-up interview after this post first appeared Wednesday that he's planning to file bar complaints against Edwards and Cassell for inadequately vetting their client's story. "I'm planning to file disbarment charges against the two lawyers who signed this petition without even checking the manifests of airplanes or travel itineraries, et cetera," he said. "I'm also challenging the young woman and the lawyers to level those charges against me outside of the courtroom, so that ] can sue them for defamation.....Finally, I’m challenging the woman to file criminal charges against me because the filing of false criminal charges is a crime." The motion accuses Prince Andrew of similar actions, asserting that “Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell’s apartment), in New York, and on Epstein’s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls).” Previous press accounts have reported on Prince Andrew’s friendship with Epstein, who was known as a philanthropist and supporter of scientific research before the criminal investigations began nearly a decade ago. However, the earlier accounts stopped short of accusing the prince of sexual involvement with girls Epstein procured. In a 2011 Vanity Fair story, Prince Andrew denied any such contact. While a Buckingham Palace spokesman did not respond to POLITICO's query about the matter on Wednesday, the palace issued a denial to several British news outlets Friday. "This relates to long-standing and ongoing civil proceedings in the United States, to which The Duke of York is not a party. As such we would not comment on the detail, However, for the avoidance of doubt, any suggestion of impropriety with underage minors is categorically untrue," the statement said. Prosecutors said in a 2007 draft letter they'd identified 40 young women who could be considered victims of Epstein’s illegal acts. Many of them filed lawsuits or claims against Epstein and reached out-of-court settlements for amounts that were not disclosed. EXHIBIT R HOUSE_OVERSIGHT_012033

While “Jane Doe #3” is unidentified in this week’s court filing, her story appears to track with that of a woman who sued Epstein in 2009 and settled with him later that year. She apparently granted an on-the-record interview to Britain's Daily Mail in 2011. Some of the fascination with Epstein on the part of tabloids and glossy magazines stems from his ties to former President Bill Clinton. In 2002, Epstein provided his 727 to Clinton for a trip to Africa to study anti-AIDS programs. Celebrities such as Chris Tucker and Kevin Spacey came along for the ride. The new court filing makes no mention of Clinton, Tucker or Spacey. The federal investigation obtained manifests for Epstein’s private jet travel, but prosecutors never charged anyone besides the investor with involvement in obtaining or using underaged girls for sexual purposes. The new court filing says this result is in part due to the fact that Epstein’s legal team—which included such heavyweights as former independent counsel and solicitor general Ken Starr, trial lawyer Roy Black, and Dershowitz—negotiated a deal that precluded the feds charging anyone as a co-conspirator. Lawyers for Jane Doe #3 argue in the new motion that Dershowitz put this language in the agreement to protect himself. However, the law professor told POLITICO he didn’t negotiate that deal and it wasn't aimed at protecting him. “I had nothing to do with drafting the non-prosecution agreement.” he said. Dershowitz added that the last draft of the agreement mentioned four people by name who wouldn't be prosecuted and he was not among them. All were regular associates or assistants of Epstein, the lawyer said, adding that the final language removed those names and simply barred federal prosecutors in South Florida from going after any potential co-conspirators. Epstein and his lawyers fought hard to prevent records about his plea negotiations from being turned over to victims’ attorneys. However, U.S. District Court Judge Keith Marra ruled last year that the victims are entitled to examine those records to prepare their case against the government. Epstein, Black and others appealed that decision to the Atlanta-based | lth Circuit Court of Appeals, but it ruled in April of this year that no privilege protects plea negotiations in this sort of dispute. Edwards and Cassell did not respond to requests for comment for this post, including an inquiry about their response to Dershowitz's comments. However, the pair appear to be pressing forward with the victims’ rights lawsuit, which seeks to unravel the no-federal-prosecution deal cut for Epstein in 2007. UPDATE (Wednesday, 7:18 P.M): This post has been updated with further comment from Dershowitz. EXHIBIT R HOUSE_OVERSIGHT_012034

-------- Original message -------- From: Abi Schwinck Date:16/01/2015 05:16 (GMT+07:00) To: Pink Jean Luc Brunel Jeff Fuller Subject: FW: Victoria From: Erik Bechtol [mailto:[email protected]] Sent: Thursday, January 15, 2015 5:12 PM To: Abi Schwinck Subject: Victoria Hey Abi! Hope you’re well. :) I’ve just had a conversation with Victoria, and she isn't comfortable remaining with MC2 with all the drama going on right now in the press. She's asked me to contact you on her behalf. Please let me know if you see any issue with this. Thanks so much! Erik Bechtol Agency Director Page Parkes Houston The Page Parkes Building 1535 West Loop South, Suite 110 EXHIBIT S$ HOUSE_OVERSIGHT_012035

Houston, TX 77027 P: 713 807.8222 F: 713 807 0055 EXHIBIT $ HOUSE_OVERSIGHT_012036