Filing II 17175578 Electronically Filed 08/15/2014 08:06:39 PM IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR DADE COUNTY, FLORIDA CIVIL DIVISION JEAN-LUC BRUNEI. Civil Action No.: Plaintiff, vs. TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. VERIFIED COMPLAINT FOR EOUITABI,E RELIEF AND DAMAGES COMES NOW the Plaintiff, Jean-Luc Brunel, by and through undersigned counsel, and sues Defendants Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org for equitable relief and defamation, and states as follows: 1. Venue is proper in Dade County, Florida as Defendants Tyler McDonald and Tyler McDonald d/b/a Yi.Org do business in Dade County, and Plaintiff Jean-Luc Brunel resides in Dade County, Florida. 2. Florida Statute 48.193(1)(aX1) ("long-ann") authorizes service on both out-of-state Defendants. 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANTS 4. Plaintiff Jean-Luc Brunel ("Brunel") is the owner of a modeling agency known as "MC2 Model Management" ("MC2"). MC2 began operations in October 2005 and has offices in New York, Miami, and Tel Aviv. 1 EFTA01107970