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