EFTA00599855

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. 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 ex Trafficking Model Scout" warning about the 
dangers of deregulated modeling agencies in the M. 
underage teenage 
m 
rk
Given the growing number of modeling agencies that transport
foreign 
countries into the United States and the growing sex trade of underage girls in the 
. 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 agencie 
w York and Paris. According to media 
reports, Diane Sawyer produced a segment for 
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 
37 
EFTA00599895

prevent depositions. "Trawling for 5' I I" 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 
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 Jerome 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 stun "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 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 
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." 
38 
EFTA00599896

http://slastrytoday.org/that-gorgeous-underage-ad-modcl-may-be-trafficked-and-owned-
regulation-for-agencies-to-stop-child-sex-traffickine 
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 S100. 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. 
Slaver, 
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 5'1 I" 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 ite traffickers have to do is pull out a magazine or phone with videos on it. 
39 
EFTA00599897

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 itflourishes 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. sheiworking 
to change with this thing she recognized to be permeating the industry. That is courage. 
Regulating Modeling Agencies to Help Prevent Child Sex Trafficking 
Conch ita Samoa' 
Posted: 02/10/2012 8:49 pm 
In 2010, Jezebel, an online site, published "The S x Trafficking Model Scout" warning about the 
dangers of deregulated modeling agencies in the M. 
siii 
Given the growing number of modeling agencies that transport underage teenager 
m foreign 
countries into the United States and the growing sex trade of underage girls in the 
. 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 
iii 
over two decades with a succession of agencie ' 
w York and Paris. According to media 
reports, Diane Sawyer produced a segment for 
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 
EFTA00599898

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' I I" 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 fcc 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 
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 Jerome Bonnouvricr. "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. 
"I said, 'I 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 
41 
EFTA00599899

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." 
42 
EFTA00599900

http://files.walistreetfolly.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 
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 M. 
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 — l= 
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 
EFTA00599901

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 I are the only two partners and owners of MC2 Model Management," [Jeffrey] Fuller 
said. [MC2 President] 
44 
EFTA00599902

http://www.washingtonpost.com/news/volokh-conspiracy/wp/20I 4/04/21/eleventh-ci rcu it-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 I 1th 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. 
I lere arc the important facts, taken from the 1 1 th 
opinion: The case arose in 2006, the 
FBI began investigating allegations that wealth Investor Jeffrey Epstein had sexually abused 
dozens and dozens of minor girls. The M. 
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 Doc No. I 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-counsel, 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 
EFTA00599903

On July 7, 2008. Edwards and I filed a petition alleging that Jane Doc No. I 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 
w
qualified as "crime victims" under the CVRA. The district court later rejected the 
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. 
make the case for such a remedy, we moved for discovery of 
the correspondence between the M. 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 I I 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 inTeelllelli was a possible remed% 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 
ruline, that we could rthie‘A 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., In re Chrysler Motors Corp. Overnight Evaluation Program Litig.. 86012.2d 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 attorneys did not need special protection: 
As a 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 
EFTA00599904

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 (11th Cir. 2003) ("[T)he 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 bit 
of the denial of the privilege, and any 
consensus among the states, Jaffee v. Redmond, 518 
I. 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 M. 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.. 
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 Ass iate Deputy Attorney General with 
the 
. Justice Department (1986-88), and an Assistant M. Attorney for the Eastern District of 
(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 E. District Court Judge for the 
District of Utah in 2002.1n 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 
EFTA00599905

----- Original message -----
From: Jolanta MODILINOS 
Date:15/10/2014 4:46 PM (GMT+02:00) 
To: Jean Luc Brunel 
Subject: 
Dear Jean Luc, 
Flops 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.. 
I am 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 
panyins 7-4, Kaunas 
Sv. Stepono 7, Vilnius 
teffax:+37037323257 
cell:+37069816103 
folantamodilinos com 
inlomodihnos.com 
www.modffinos.com 
EXHIBIT B 
EFTA00599906

From: *Vladimir Yudashkin Q 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 I 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 intemet 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. I 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 
Vladimir Yudashkin 
Director 
EXHIBIT C 
EFTA00599907

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, I 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 
MEGA 
PARTNERS 
MANUELA W MARTINEZ 
international Petri= 
Phone: +66 11 3818.4800 
Direct: +65 11 3818.4827 
Cell.: 
+551188668.0080 
megentodelbrasilcom.br 
EXHIBIT D 
EFTA00599908

Original Message----
From: Lorraine <lorraine@mc2mm.com> 
Organization: MC2 MM 
Reply-To: <lorraine©mc2mm.com> 
Date: Friday, August 27, 2010 at 8:49 PM 
To: <jeff@mc2mm.com>, Jean Luc Brunel <jeanluc@mc2mm.com>, Pink 
<pink©mc2mm.com> 
Subject: FW: Press Inquiry from AFP (Agence France Presse) 
Videographer--Michelle Stockman 
>----Original Message 
>From: Michelle STOCKMAN [mailto:Michelle.Stockman@afp.com] 
>Sent: Friday, August 27, 2010 11:03 AM 
>To: lorraine©mc2mm.com 
>Subject: Press Inquiry from AFP (Agence France Presse) 
>Videographer—Michelle Stockman 
>My name is Michelle Stockman and I am a video journalist for Agence France 
>Presse, the French newswire. We produce 1.5 to 2 min. videos that are 
>dlstributed internationally to broadcast clients in Europe and Asia, and 
>internet clients worldwide. In preparation for Fashion Week, my print 
>colleague and I are interested in doing a piece on trends in casting 
>models 
>of color. I 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 I would like to set something up for Monday 
>or 
>Tuesday. I can come to you as I 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 
EFTA00599909

>917-533-3261 
>www.youtube.com/AFP 
>Agence France-Presse is the 
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. It 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://www.afp.com 
EXHIBIT E 
EFTA00599910

Sept 4.0q, Sacrum Yob* 
---- Original message -----
From. Michael Sanka 
Date:12/12J2014 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 tc 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 ycu since they all told me "We know Jean 
Luc for more than 20 years and ail 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 representea them". 
I 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 lo have it stop and have the people write an official letter to say that it's not the truth .. 
I will keep you posted of course but it's really bad for us and the scouting. 
Best regards 
Michael Sanka 
3104021028 
EXHIBIT F 
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FOX 
Ann: Scouting division MC? 
We took notes of your comments and the girls that you like on our websitc 
We know Jean Luc Brunel and we always work with him since more than 10 years all 
those years and nes er had any problems. 
All the girls he represented from us nes a had any problems. they were working has e 
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 
met and you interest to represent their daughters and of course they google it and saw all 
the had articles about sex trafficking they were scared and I was myself speechless since 
we know that it's not true but it spa hard for us to explain to the parents. 
So of course for the moment till all is clarified 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 
38CAC) 
We are sum but you really need to clarify escry-thing. till then we will base to cease any 
collaboration and we will have to refuse to let you represent any of our models 
Sure you understand 
Sandra Petkanic 
Fox Fashion Agency 
800(410 11000. SwittOOTTA8 35 v SW '2 
www.loxmodetcom 
aniaN: Waffle. tsezempro.yu 
MI .381 
3346414 lig 10 •381 11 3226202 
EXHIBIT G 
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1
 
Az part of your employment with MC Square 
2 
did you live in New York, for a time? 
3 
A 
I'm sorry, but I take the Fifth. 
4 
Q 
Have you ever heard any model of MC Square 
5 
who at the time of being a minor, that means under 
6 
the age of eighteen, made an accusation that 
7 
Jean-Luc Burnel acted inappropriate with her? 
8 
A 
Never. And that is something that I will 
9 
not answer. And I said never because even when 
10 
peoples come and ask me I will always say the truth 
11 
regarding that. 
12 
I know Mr. Brunel for the longest --
13 
maybe eight years. And I always said what I know. 
14 
I never saw and I never knew that he did anything. 
15 
So I know that. And 
the truth. 
16 
Never. I never heard anybody accusing Mr. Brunel 
17 
or complaining about Mr. Brunel. Nothing. 
18 
Q 
That means -- that means at any time no 
19 
model, no minor model came to you and said, you 
20 
know, "Maritza, look what just happened to me", that, 
21 
"something bad happened to me". 
22 
A 
Maybe a model came and told me, "Maritza, 
23 
look what happen to me. I don't have any money," or 
24 
"I don't have a place to live". Or, "Look, I didn't 
25 
get my ticket", or whatever. 
EXHIBIT H-I 
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43 
1 
2 
tot. OBRONT: Well, I would object, because 
3 
of circumstances. 
4 
BY MR. DAVID: 
5 
0 
But you said before that you never heard 
6 
anything that would indicate that Jean-Luc Burnel 
7 
behaved inappr~•priately with -- with any models, 
q 
especially any minor models that MC Square may have 
g 
had. 
0 
Is that correct? 
1 
A 
Yeah, I said what is the truth. Nobody 
2 complain to me. Nobody -- your question was very 
3 
clear, has any girl came to you and complain about 
4 
sexually, you know, involved with Mr. Brunel. 
5 
0 
Right. 
6 
A 
And my answer was no. Nobody came to tell 
7 
me. I never taw. I never knew. His personal life 
B 
was ni.t my problem. 
9 
0 
D you have any actual knowledge, that is 
O 
to say were you present or did you see with your own 
j 
eyes, any minor models go with Joan-Luc Burnet to 
2 
Jeffrey Eputein's home, CA any party of his? 
3 
MR. OBRONT: Objection. 
4 
THE WITNESS: I'm sorry, but I take the 
5 
Fifth. 
EXHIBIT H-2 
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