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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 Plaintiffs 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 II —- INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UPON PLAINTIFF BRUNEL - AS TO DEFENDANT JEFFREY EPSTEIN 67. The allegations contained in paragraphs 1 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 HOUSE_OVERSIGHT_011922