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Legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (spelled Bruhnel in document). The filing opposes Plaintiff Jane Doe's motion to compel Bruhnel to appear for a deposition, arguing that Bruhnel is a French citizen who has left the US with no plans to return and cannot be compelled by the Court to return. The document asserts that the Plaintiff should use the Hague Convention or other international mechanisms to secure testimony abroad and accuses Plaintiff's counsel of misrepresentation and failure to follow proper procedure.

A legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party Jean Luc Bruhnel (spelled 'Bruhnel' in document) in the case of Jane Doe v. Jeffrey Epstein. The filing opposes a motion to compel Bruhnel's deposition, arguing that he is a French citizen who has left the U.S. with no plans to return and cannot be compelled to appear under Federal Rules. The document alleges misrepresentation and nonfeasance by the Plaintiff's counsel and suggests using the Hague Convention to secure testimony abroad.

This document is a legal response filed on March 12, 2010, by attorney Tama Beth Kudman on behalf of non-party witness Jean Luc Bruhnel (likely Jean-Luc Brunel) in the civil case Jane Doe v. Jeffrey Epstein. Bruhnel opposes the plaintiff's motion to compel his deposition, arguing that he is a French citizen who has left the United States and cannot be legally compelled to return for testimony. The filing claims the plaintiff's motion is frivolous, notes that previous deposition dates were canceled by agreement, and suggests the plaintiff should use the Hague Convention to secure testimony abroad.