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66. In view of this information suggesting Brunel could provide significant evidence of Epstein’s trafficking in young girls for sexual abuse, Edwards had Brunel served in New York for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit “II.” Before the deposition took place, Brunel’s attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that relevant period of time attached Exhibit “JJ”. As a result, Edwards filed a Motion for Contempt, attached hereto as Bxhibit “KK” (Because Epstein settled this case, the motion was never ruled upon.) 67. | Edwards was also informed that Epstein paid for not only Brunel’s representation during the civil process but also paid for legal representation for Sarah Kellen (Epstein’s executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein’s personal pilot), Dave Rogers (Epstein’s personal pilot), Larry Harrison (Epstein’s personal pilot), Louella Rabuyo (Epstein’s housekeeper), Nadia Marcinkova (Epstein’s live-in sex slave), Ghislaine Maxwell (manager of Epstein’s affairs and businesses), Mark Epstein (Epstein’s brother), and Janusz Banasiak (Epstein’s house manager) It was nearly impossible to take a deposition of someone that would have helpful information that was not represented by an attorney paid for by Epstein. See Edwards Affidavit, Exhibit “N” at §11. 26 HOUSE_OVERSIGHT_010591