EFTA01122242

fal IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY. FLORIDA. 
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CASE 11.113EP 
1402134ISCAO 
PLAINTIFFS) 
JEAN-LUC BRUNEI. 
VS. DEFENDANT(S) 
JEFFREY EPSTEIN. 
TYLER MCDONALD. 
TYLER MCDONALD 
D/B/A YI.ORG 
CLOCK W 
THE STATE OF FLORIDA:TO EACH SHERIFF OF TIE STATE, YOU ARE COMMANDED to sane EH Sinn* 
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CLERK OF COURTS 
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AMERICANS WITH DISABILITIES ACT OF 1990 
ADA NOTICE
"If you are a person with a disability who _needs any accommodation
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participate in this _proceeding, you are entitled, at no cost. to you,_ o_ the p 
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certain assistance. Please contact the Eleventh Judicial Circuit
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EFTA01122242

O EN LA CORTE DE CIRCUITO DEL UNDECIMO CIRCUITO JU DICIAL EN Y PARA EL CONDADO DE MIAMI-GADE LA FLORIDA 
0 EN EL TRIBUNAL DEL CONDADO EN 'e' PARA CL CONDADO MLAMI-DADE. LA FLORIDA 
DIVENON 
0 CIVIL 
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EMPlAZAMIENTO DE ACCION CML 
(b) NOT1FICACION PERSONAL 01 PERSONA NATURAL 
DEMANDANTE(S) 
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NUMERO DE CAS° 
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ode de le deinende an •10 piib el 71015017~9(7) 771~015057 ambo 
HARVEY RUVIN 
Secretarie del Tribunal del 
POR: 
Condado 
COMO Beenden° Adninlo 
Ley para Estadounidenses con Incapacidades 
"Si usted es una persona inhausválida que necesita hater arreglos para poler partcipar 
en este proceso, usted tiene derecho, san gasto alguno, a que se le provea cierta ayuda. 
Por favor péingase en contacto con el Coordinador de ADA en el Onceavo Distrito 
Judicial ubica-do en el Lawson 
urtho 
NW 
2702, Miami Fl 33128, Teléfonos 
TDD 
Fax 
por lo mens 7 
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ga a para su comparecencia en los r una e_; 
anmediatamente después de recibir esta notificacién si el tiempo antes dc la 
comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitación 
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EFTA01122243

0 AU TRIBUNAL DU ONEEME ARRONDIE:MENT JUDICIARE DANS ET POUR ISAMIOADE FLORIDE. 
O AU TRIBUNAL DE JUGEMENT ET POUR LE DEPARTENT DE TENA-DADE FLORIDE 
DIVISION 
0 
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PLAINTE(S) 
A (AUX) ACCUSE(S) 
CONVOCARION D I ACTION CIVILE 
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NUMERO DE CAS 
VS. CONTRE ACCUSE(S) 
HEURE IN 
ADRESSE: 
IMPORTANT
poursuites Manu ont ate enterprises œntru aura. vous errez 20 fours coraeorots a parer a de ka dire de rassIgration de ale 
Cabal pour deposes une response ease a ta pro (Seine aptes de ce Mine Un secte coup de teleçœne est nellisant pour vous 
prenez Vous ewe oasis de depose batte anise talle, nec menin du numem de douer *dessus el du nom des battes 
noroises id. si vous souhaitez que in tribal enterait von Causa Si as ne agate pas este repense ecrite dans In Mi nette van 
natta de perdre YI couse muez que sen salaire votre arpent et vos ben pomma en usa pas la sa, axai primats ullenaur do 
niai. Il y a daubes obligations juridiques et vous pouvez roquet Ws satins iniffellatc d'un avocat. Si voie ne connaissez pas dace. 
voue pOumez lekephOrM a un .avive relatante cavala ou a th butas dam:stance )aequo (Routard a tarnualte de teuton«) 
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reportes awe b Cirta du Tribunal. L'adresse watt du bureau du Greffer est Io Dada County Couilhouse. L'adresse du tharseet 
redresse des succursales sent *ana ci-dessous parr sotte oonvenen 
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LIAT OE LA FLORIDE A chaque te il de refait vota etes otage de presenter cette citation et une photocpie de la plaines te 
ce document SW recouse (e) a-destes. 
Adresse. 
HARVEY FtliVIN 
Greffier do Tribunal 
PAR: 
COIME GIEFFER ALUttaT 
DATE ON: 
ACT DE 1990 POUR AMERICAINS HANDICAPES 
AVIS DE I' ADA 
"Si vous êtes une personne handicapée qui a besoin d'accommodement pour pouvoir 
participer à cette procédure, vous avez le droit, sans aucun coût, d'avoir de l'aide à votre 
disposition. S'il vous plaît contacter le Coordinateur de FADA du Tribunal de l'Onzième 
Circuit Judiciaire, Lawson Eassak6sithottse
W 1" 
02, 
Miami, FL 33128, Téléphone I
ffl
; TDD 
Fax 
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moins 7 jours avant la date de comparution au tribunal, onbien immédiatement après 
avoir reçu cet avis si la date avant la comparution est moins de 7 jours; si vous avtz une 
incapacité pour  entendre ou parler, appelez  le 711." 
OMET. 07o Rev (lilt 
dort% webinlabanc wimMninidedeSrli.Con 
EFTA01122244

0 NAN TRIBUNAL OfIZYEM ANNONDISMAN .11DISIE NMI E POU kausoAnc COUNI Y, FLORIDA 
0 NAN TRINNALEPOU TRIBINAL NAN MIAMI-DADE COUNIY, FLORIDA 
DNIZYON 
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Yo entre yon aksyon kont oumeum. Ou genyen 20 jou kalandnye apres ou recevoi somasyon-an pou enregistre c ovan 
grebe tribunal-sa, yon reponse pa eat attache nee plent-la. Yon apal pa teletan ka kapab prolege-ou. Se yon repents pa 
alto ou ma numem ka-a ki sou let pagela avec nom rurune-yo ki sou papie-sa oblige esi si ou vle ke IribunaHa !Bade 
position-au cou ka-a. SI ou pa enregistre noponotfrou a Mauro ou capab pedu ka-a san tribunal le pa anounce-ou or' yen, 
ou capab pedu ragen 01/ Mc byen ou. Genyen lot demands. Ou ka besoin !arena yon avoka tout de suit. Si Ou pa Conan yon 
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pa sal pou evoke ',Sayan ou pleyan-yo ke norNi ama-a et enregistre reponee-la nan tribunal-la kl localize nan svek Shkrete 
Tribinal. Adres amber biwo Secrete a se Dade County Courthouse. Adres biblical le, ak rakes lot Iribinal yo nan lis ki r nba a 
pou ou ka peen yo titer. 
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"Si ou se yon moun lei enlim e ou bezwen akomodasyon pou ou patisipe nan pwosedi sa a, 
ou gen dwa pou yo ba on kilt ed san ou pa gen pou ou peye. Silvouple kontakte 
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bous 
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ågamsigja.2702, Miami, Fl 33128, Telefon 
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omwen 7 jou enven ou gen randsva I pou 
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pale, rele 711." 
Nimes*, minim evoke a. 
Address: 
DATE: 
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EFTA01122245

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 EPSTETN. 
TYLER MCDONALD. TYLER 
MCDONALD D/B/A/ YLORG 
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: 
I. 
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 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 is appropriate there. 
Florida Statute 47.011. 
2. 
Florida Statute 48.193(1)(a)(I) ("long-arm") authorizes service on both out-of-state 
Defendants (Tyler McDonald. and Tyler McDonald d/b/a/ Yi.Org). 
EFTA01122246

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. 
7. 
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. 
9. 
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 
2 
EFTA01122247

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. 
II. 
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 I 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 intemet falsely 
implicating Plaintiffs as being involved with illegal activities with young models. This is 
3 
EFTA01122248

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 Plaintiffs behalf was an e-mail dated August 27, 2010 from 
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. 
16. 
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 
4 
EFTA01122249

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. 
2I . 
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. 
stated in a 2012 
deposition that Plaintiff Brunel had never done anything inappropriate or illegal with any under-
age model. (Exhibits HI & H2 -Transcript of Deposition of 
24. 
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 
of the website Jezebel (Composite Exhibit A. p.2-7). 
5 
EFTA01122250

25. 
The deposition testimony of 
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. As a 
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. 
As a 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. 
At no time did Epstein ever publicly state that Plaintiffs had no role whatsoever in the 
Epstein's illegal activities. 
30. 
As a result 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, 
11-12-14). 
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. 
6 
EFTA01122251

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. 
As a 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 Brunel 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. 
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EFTA01122252

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). 
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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 Yi.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 stale 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 
9 
EFTA01122254

websitcs 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 Yi.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 arc 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 
59. 
The allegations contained in paragraphs I 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 I through 44 above are re-alleged and 
incorporated herein by reference. 
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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 Plaintiff's 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 III — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON 
PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 
67. 
The allegations contained in paragraphs I 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 
II 
EFTA01122256

COUNT IV - EQUITABLE RELIEF FOR LOSS OF BUSINESS AND REVENUE - AS 
TO DEFENDANTS TYLER MCDONALD AND MCDQNALD Dift/A,YLORG 
71. 
The allegations contained in paragraphs I 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; trial 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 YI.ORG 
75. 
The allegations contained in paragraphs I 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. 
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EFTA01122257

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 VI — EQUITABLE RELIEF FOR REPAIR OF BUSINESS REPUTATION - AS 
TO DEFENDANTS TYLER MCDONALD & TYLER MCDONALD D/B/A/ YI.ORG 
80. 
The allegations contained in paragraphs I through 3 & 45 through 58 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 
Joc Titone 
Attorney 
FL BAR #: 203882 
621 S.E. 51h Street 
Pompano Beach. Florida 33060 
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EFTA01122258

VERIFICATION 
STATE OF FLORIDA 
COI JNTY OF/C2.4.4eI e/he 
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JEAN-LLIC BRUNEL. being duly sworn according to law. upon his oath, deposes and says: 
I have mad the fore-going complaint and all the allegations contained ther/in All such 
allegations um true based upon my personal knowledge, infurtnutioy and belief. 
i 
Sworn and albscribed to before me this  / 
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EFTA01122259

COMPOSITE 
EXHIBIT A 
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EFTA01122260

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 ofJustice 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.) 
• 
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. Attorney's office then settled in a 2007 plea deal. The first 
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EFTA01122261