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. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMES NOW, the Defendant, Jeffrey Epstein, a resident of the United States Virgin Islands, by and through his undersigned counsel, and files this Motion to Dismiss, and as good grounds therefore states as follows: I. In complete disregard for Florida's procedural rules and Florida Statutes Section 48.031(1)(a), on March 10, 2015, Plaintiffs improperly attempted to serve Defendant Jeffrey Epstein in New York by leaving process with a woman at a location that was not Mr. Epstein's usual place of abode. Plaintiffs never even filed a Notice of Service of Process in connection with that failed attempt. 2. The undersigned counsel promptly filed a motion to quash on behalf of Mr. Epstein in April 2015, which motion included Mr. Epstein's affidavit confirming the location of his residence and usual place of abode in the United States Virgin Islands. 3. Plaintiffs waited a full year to respond to that motion to quash and in their response, perhaps conceding that the attempted service was improper, asked this Court to EFTA00585821