This document is the first page of an Amended Verified Complaint filed on January 26, 2015, in the Eleventh Judicial Circuit of Florida. Plaintiffs Jean-Luc Brunel and MC2 Model & Talent Miami, LLC are suing Jeffrey Epstein and Tyler McDonald (d/b/a Yi.Org) for defamation and other legal relief. The text establishes proper venue in Dade County based on the residence/business locations of the parties and the location where the alleged acts by Epstein occurred.
| Name | Role | Context |
|---|---|---|
| Jean-Luc Brunel | Plaintiff |
Suing individually; noted as residing in Dade County, Florida.
|
| Jeffrey Epstein | Defendant |
Being sued for legal relief, equitable relief, and defamation. Alleged to have committed specific acts in Dade County.
|
| Tyler McDonald | Defendant |
Being sued individually and doing business as Yi.Org; noted as an out-of-state defendant doing business in Dade County.
|
| Name | Type | Context |
|---|---|---|
| Eleventh Judicial Circuit of Florida |
Jurisdiction where the complaint is filed (Dade County).
|
|
| MC2 Model & Talent Miami, LLC |
Co-plaintiff alongside Brunel; has an office in Dade County.
|
|
| Yi.Org |
DBA (Doing Business As) for Tyler McDonald.
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT_011912'.
|
| Location | Context |
|---|---|
|
Location of the court, residence of Brunel, office of MC2, and place where causes of action accrued.
|
"sues Defendants Jeffrey Epstein, Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for legal relief, equitable relief and defamation"Source
"The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there"Source
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