IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. MEMORANDUM IN OPPOSITION TO MOTION FOR RULING ON SERVICE OF PROCESS Having already once received this Court's indulgence for Plaintiffs' total disregard of Florida's procedural rules governing proper service of process and a 120-day extension of the time within which to effect service (effectively providing Plaintiffs with a 2-year service window), Plaintiffs again ignore Florida's jurisdictional prerequisites with their improper service attempt and ask this Court to bless their misconduct for a second time. Service of process in this case is governed by Florida law. Florida Statutes Section 48.031 (1)(a) requires that service of original process be made by personally delivering a copy of the complaint, petition or other initial pleading or paper to the person to be served, or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents. Plaintiffs have not met a single one of these requirements in this case. When Plaintiffs first filed their complaint in August 2014, Defendant Jeffrey Epstein was not even a party. Plaintiffs amended their complaint in January 2015 to assert two non-business counts against Mr. Epstein personally and caused a summons to be issued on February 9, 2015. In more than two years since Plaintiffs amended their complaint to include Mr. Epstein as a party, they have not made a single attempt to serve Mr. Epstein at his residence and usual place of abode in the United States Virgin Islands. Plaintiffs made a first half-hearted attempt on March 10, 2015 to serve Mr. Epstein in New York by leaving process with a woman at a location that was not Mr.