Case Document Entered on FLSD Docket Page of Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works No Amended Verified Complaint for Legal Equitable Relief and Damages Joe Titone Attorney FL Bar S.E th Street Pompano Beach Florida Fax Joetitone708 comcast.net COME NOW the Plaintiffs Jean-Luc Brunei 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 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 Brunei resides in Dade County Florida and Plaintiff 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 i appropriate there Florida Statute Florida Statute a 223long-arm authorizes service on both out-of-state Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org Jurisdiction is proper in the Circuit Court as this action seeks reli ef in excess of fifteen-thousand dollars FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN Plaintiff Jean-Luc Brunei is the owner of Plaintiff modeling agency known as Model Talent Miami MC2 began operations in October and has offices in New York Miami and Tel Aviv Defendant Jeffrey Epstein 223Epstein 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 Plaintiff Brunei and Epstein have known one another since the incepti on of Plaintiff MC2 Plaintiff Brunei 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 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 Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works First after the initial criminal charges against Epstein were filed in Palm Beach County Plaintiffs were widely implicated in the media as being 223linked to Epstein These false stories cau sed both Plaintiffs a tremendous loss of business Plaintiffs lost multiple contacts and business in the modeling business as a direct result of Epsteins illegal actions For example several photographers will not work with MC2 due to the adverse publicity surrounding Epstein and his illegal activities and the publicity falsely linking Plaintiffs with those acti vities namely sex trafficking Composite Exhibit A 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 Brunei he had 223found out some information from some friends of his and that he could not associate his name with MC2 This statement by Avedon was no doubt a reference to the alleged and false links between Plaintiffs and Epsteins illegal activities with under-aged girls This incident clearly illustrates an example of lost business on Plainti ffs behalf The second example of a business relationship that was terminated due to Epsteins 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 223found some article in internet which changed her position and she preferred to be placed with another agency This was relayed to Plaintiff Brunei by e-mail dated October This a mply demonstrates that Epsteins intentional illegal activities continue to cost Plaintiffs business income Exhibit att ached A third example of a lost business relationship can be found in an e-mail dated October Exhibit 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 another example of a false link between Epstein and Plaintiffs costing Plaintiffs business income A fourth example of a lost business relationship can be found in a second e-mail dated October Exhibit attached Manuela Martinez of Mega Partners a Brazilian modeling agency states to Plaintiff Brunei 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 A fifth example of a lost business relationship can be found in an e-mail dated on Plaintiffs behalf was an e-mail dated August from Michelle Stockman of Agence France Presse Exhibit attached Agence France Presse is a newswire service with a worldwide reach Stockman wanted to meet with Plaintiff Brunei to arrange a model shoot with MC2 However due to the adverse publicity surrounding Plaintiffs as a result of Epsteins illegal activities Plaintiff Brunei was forced to forego and lose this business opportunity because he needed to keep a low-p rofile at this time A sixth example of lost business due to Epsteins intentional and illegal activities can be found in an e-mail dated December Exhibit attached Michael Sanka a talent scout who had worked with Plaintiffs for a number of years informed Plaintiff Brunei that he cannot sign any new models for Plaintiff Bruneis MC2 agency due to the false sex trafficking allegations online Sanka goes on to state that Plaintiff Bruneis MC2 agency will not attract any new models if Plaintiff Brunei does not clear up the false allegations A seventh example of lost business due to Epsteins intentional and illegal activities can be found in an e-mail from Fox Fashion Agency Exhibit attached This e-mail clearly states 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 Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works Before the false links between Plaintiff and Epstein surfaced Plaintiff Brunei was earning a great deal of revenue from MC2 Miami The false links between Plaintiffs and Epstein began to surface online in about Then in Plaintiffs received a letter of credit from Epstein at interest Plaintiffs then made an investment totaling one-million dollars with Elite Paris to start a company Next Plaintiff Brunei started the company Management to work with Elite Models in Paris Plaintiff had to close it almost immediately because Elite didnt send any models to Plaintiff MC for fear of being linked to Epstein 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 Brunei lost his investment of ne-million dollars because of this loss of business Plaintiffs lost potentially ten-million dollars in profits due to th is initial one-million dollar loss Additionally a former financial controller of MC2 Maritza Vasquez stated in a deposition that Plaintiff Brunei had never done anything inappropriate or illegal with any underage model Exhibits HI H2 Transcript of Deposition of Maritza Vasquez 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 Com posite Exhibit A The deposition testimony of Maritza Vasquez referred to above clearly demonstrates that Plaintiff Brunei has clean hands and was never involved in sex trafficking All of Plaintiffs damages ca me solely from Epsteins conduct Additionally Plaintiff Brunei 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 As a result of these delays Plaintiffs lost a considerable amount of time money International travel is a significant component of Plaintiff Bruneis MC2 modeling business Plaintiff Brunei has been forced to cancel his latest visa application as a result of the delays Exhibit Composite Visa Docs As a result of the notoriety and tremendous publicity surrounding Epsteins criminal charges and the media linkage of Epstein to Plaintiffs regarding illegal activities Plaintiffs lost a tr emendous amount of business and revenue Plaintiff Bruneis 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 At no time did Epstein ever publicly state that Plaintiffs had no ro le whatsoever in the Epsteins illegal activities As a result of Epsteins illegal activities and his association with Plaintiffs Plaintiffs continue to lose money and suffer damages to this day Exhibit attached Jeff Fuller email Plaintiff Brunei will need to spend millions of dollars in order to restore his business to what it was once worth money that the Plaintiff Brunei does not have Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works Plaintiff Brunei 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 attached Second Plaintiff Brunei was also told by Epstein to leave the Palm Beach area in anticipation of a deposition of Plaintiff Brunei in a criminal case against Epstein On the direct advice of Epstein Plaintiff Brunei went to Europe and Asia for a period of time This was done for the sole purpose of delaying Plaintiff Brunei deposition As a direct result of Plaintiff Bruneis travels his deposition was delayed twice When it was finally scheduled for November Plaintiff Brunei was in fact available Exhibit attached However a medical emergency in the family of his attorney further delayed this deposition Exhibit attached It was never res cheduled and he was never deposed This was a blatant example of obstruction of justice in the criminal case Epstein was solely responsible for telling Plaintiff Brunei to leave the area Plaintiff Brunel lost a huge opportunity to cl ear his name and that of his agency Plaintiff MC2 Third as a result of all of the facts stated above Plaintiff Brunei was under tremendous psychological pressure throughout this period of time This psychological pressure resulted in Plaintiff Brunei avoiding business contacts as set forth above This pressure also directly caused Plaintiff Brunei to avoid certain social contacts during this period of time Plaintiff Brunei became extremely withdrawn and anxious at this time Epsteins conduct was the direct cause of Plaintiff Bruneis psychol ogical state The press was reporting extensively on the lurid details of Epsteins illegal activities with the under As stated above the press reports were erroneously connecting both Plaintiffs to Epsteins illegal activities Composite Exhibit A attached Epsteins 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 fing er or object or full-intercourse These activities described above caused Plaintiff Brunel severe emotional distress In fact Plaintiff Brunel has recently undergone psychotherapy with a local psychologist Dr Royce Jalazo as a result of Epsteins actions and the negative results on his business Exhibits attached Plaintiff Brunel is emotionally destroyed as a result of Epsteins actions and the resultant effects on his business He has been on medications to deal with the effects of this Composite Exhibi Medical History 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 reasona ble fee for his services FACTUAL ALLEGATIONS AS TO DEFENDANTS TYLER MCDONALD TYLER MCDONALD D/B A YI.ORG Defendant Tyler McDonald 223McDonald is the owner/operator of Yi.Org and also does business as Yi.Org Defendant Tyler McDonald d/b/a Yi.org 223McDonald 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 Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works In about 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 attached hyperlink screenshot 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 These links have damaged Plaintiff Brunels reputation as an owner of a well-established modeling agency with offices in New York and Miami Plaintiff MC2 These links have also damaged the reputation of both Plaintiffs 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 Plaintiff MC2s revenues have fallen to a mere fraction of what they were before the appearance of the links on Yi.Org 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 Plain tiffs 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 Accordingly Plaintiffs have been severely damaged by information on websites hosted by Yi.Org which is maintained owned and operated by Defendants McDonald d/b/a Yi.Org and McDonald 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 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 websites they osted 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 Yi.Org and McDonald 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 The allegations contained in paragraphs through above are re-al leged and incorporated herein by reference Plaintiffs have lost a significant amount of business revenue becaus of the actions of Defendant Epstein set forth above 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 Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works 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 Grant other such relief as is appropriate COUNT II OBSTRUCTION OF JUSTICE EQUITY AS TO DEFENDANT JEFFREY EPS TEIN The allegations contained in paragraphs through above are re-al leged and incorporated herein by reference Plaintiff was forced to commit illegal acts by traveling away from the sight of the deposition and during the time period of the deposition 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 i ncurred expenses in following Epsteins commands Plaintiffs were substantially damaged as a direct result of Epsteins actions WHEREFORE PLAINTIFFS request judgment against DEFENDANT as follows A Damages in excess of fifteen-thousand dollars trial by jury and Grant other such relief as is appropriate COUNT HI INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL AS TO DEFENDANT JEFFREY EPSTEIN The allegations contained in paragraphs through above are re-al leged and incorporated herein by reference Defendant Epstein recklessly inflicted emotional distress upon Plaintiff Brunel by engaging in illegal conduct with under aged girls which was falsely linked to Plaintiffs This illegal conduct was extreme and outrageous by any standard This extreme and outrageous conduct was the direct cause of extreme emotional distress in Plaintiff Brunel WHEREFORE PLAINTIFF BRUNEL requests judgment against DEFENDANT as follo ws A Damages in excess of fifteen-thousand dollars trial by jury and Grant other such relief as is appropriate COUNT IV EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works The allegations contained in paragraphs through through above are realleged and incorporated herein by reference 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 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 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 trial by jury and Grant other such relief as is appropriate COUNT DEFAMATION AGAINST PLAINTIFFS AS TO DEFENDANTS TYLER MCDONALD AND MCDONALD D/B/A YI.ORG The allegations contained in paragraphs through through above are realleged and incorporated herein by reference Defendants McDonald d/b/a Yi.Org and McDonald published or caused to be published false statements about Plaintiffs using their domain hosting service Defendants McDonald d/b/a Yi.Org and McDonald knew or should have known that the statements about Plaintiffs were false These published statements were read by the internet users who viewe the false statements Plaintiffs business reputations were severely damaged as a result WHEREFORE PLAINTIFFS request judgment against DEFENDANTS as follows A Damages in excess of fifteen-thousand dollars trial by jury and Grant other such relief as is appropriate COUNT VI EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION AS TO DEFENDANTS TYLER MCDONALD TYLER MCDONALD D/B/A YI.ORG The allegations contained in paragraphs through through above are realleged and incorporated herein by reference 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 Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works 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 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 Grant other such relief as is appropriate Joe Titone Joe Titone Attorney FL BAR S.E th Street Pompano Beach Florida FAX Joetitone708 comcast.net VERIFICATION STATE OF FLORIDA COUNTY OF MIAMI DADE JEAN-LUC BRUNEL being duly sworn according to law upon his oath depos es and says I have read the foregoing complaint and all the allegations contained therein All such allegations are true based upon my personal knowledge information and belief signature JEAN-LUC BRUNEL Sworn and subscribed to before me this day AUGUST signature Case Document Entered on FLSD Docket Page of Westlaw Nexr Jean-Luc BRUNEL et al Jeffrey EPSTEIN et al WL Thomson Reuters No claim to original U.S Government Works NOTARY PUBLIC End of Document Thomson Reuters No claim to original U.S Government Works Case Document Entered on FLSD Docket Page of Westlaw Nexr
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