Epstein Secrets

ed long ago, "[s]ilence is often evidence of the most persuasive character."' Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

that Jane Doe might obtain in this case. DATED this 19th day of June, 2009. 19 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone (954) 522-3456 Facsimile (954) 527-8663 Flori

he most persuasive character."' Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most

Epstein was defrauded by Edwards, acting in concert with (a minor female who was sexually abused by Epstein) and Scott Rothstein (President of the Rothstein Rosenfeldt Adler law firm ("RRA") where Edwards worked for a short period of time). Epstein appears to allege that Edwards joined and Rothstein in fabricating sexu

zed long ago, "[s]ilence is often evidence of the most persuasive character.'" Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

34910 dEAUg-IvIei 61A015HOMPTIent 165 FnLerecaonlL..., blYset 06/19/2009 Page 4T 8? 3031 Jane Doe v. Epstein, et at. Page 9 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwardsarra-law.com Counsel for Plaint