Epstein Secrets

n. § 726.105(1)(a). Jane Doe has made such a showing, as explained in the next paragraph in text. 5 For this reason, Epstein’s citation of In re Stewart, 280 B.R. 268, 285 (Bkrtcy. M.D. Fla. 2001), is not on point. In that case, the plaintiff had merely made allegations without providing any support

must provide some kind of “independent evidence” of his fraudulent transfers in order to gain the inference of fraudulent transfers. The first is Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991), in which Plaintiffs who had filed a frivolous lawsuit appealed from a district court decision grantin

ovided any evidence that the Court should not draw an adverse inference – or, indeed, any evidence at all in opposition to her motion. Accordingly, Avirgan is not on point and certainly does not suggest that Jane Doe needs to provide some sort of independent evidence to obtain an adverse inference.1

tor is fraudulently transferring assets. Jane Doe fails to point to one iota of evidence that Epstein is fraudulently transferring assets. In In re Stewart, 280 B.R. 268 (M.D. Fla. 2001), proceedings were brought to set aside certain transfers of the debtor as fraudulent to creditors. The bankruptcy tr

lent] billing ... which in tum ensures that the proposed adverse inferences, should the jury choose to draw them, are not unreliable." Id. See also Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991) (holding that "the negative inference to be drawn from the assertion of the fifth amendment does not s

tor is fraudulently transferring assets. Jane Doe fails to point to one iota of evidence that Epstein is fraudulently transferring assets. In In re Stewart 280 B.R. 268 (M.D. Fla. 2001), proceedings were brought to set aside certain transfers of the debtor as fraudulent to creditors. The bankruptcy trus

inferences drawn from Fifth-Amendment-protected silence are treated as a substitute for the need for evidence on an ultimate issue of fact," citing Avirgan, supra). As belabored throughout this memorandum, Jane Doe cites no independent evidence that Epstein is fraudulently transferring assets. Accordi