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adverse publicity surrounding Epstein and his illegal activities, and the publicity falsely linking
Plaintiffs with those activities; namely, sex trafficking. (Composite Exhibit A).

10. One example of such a photographer was Michael Avedon, who worked with MC2 on
photo shoots. Avedon stopped answering Plaintiffs’ emails and phone calls after having known
Plaintiff for some time. Upon meeting Avedon out one night, Avedon stated to Plaintiff Brunel
he had “found out some information” from some friends of his and that he could not associate his
name with MC2.

11. This statement by Avedon was no doubt a reference to the alleged and false links
between Plaintiffs and Epstein’s illegal activities with under-aged girls. This incident clearly
illustrates an example of lost business on Plaintiffs’ behalf.

12. The second example of a business relationship that was terminated due to Epstein’s
intentional and illegal activities was a very recent one, involving an overseas agency, Modilinos
Model Agency. The owner stated that the model to be placed with MC2 “found some article in
internet, which changed her position and she preferred to be placed with another agency.” This
was relayed to Plaintiff Brunel by e-mail dated October 15, 2014. This amply demonstrates that
Epstein’s intentional & illegal activities continue to cost Plaintiffs’ business income. (Exhibit B
attached).

13. A third example of a lost business relationship can be found in an e-mail dated October
17, 2014 (Exhibit C attached). The director of the 1 Mother Agency, Vladmir Yudashkin, states
that a specific model will not sign with Plaintiff MC2 due to her fear that Plaintiffs’ will force
her into illegal activities. The model bases her fears upon the stories on the internet falsely
implicating Plaintiffs as being involved with illegal activities with young models. This is

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