Epstein Secrets

iewed as a form of injunctive relief, is more precisely viewed as a pre- judgment seizure of property. In any event, the name is not important. See Rosen v. Cascade Intern., Inc., 21 F.3d 1520, 1530 (11th Cir. 1994) (“federal courts look past the terminology to the actual nature of the relief request

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

the plaintiff seeks only to recover money damages do not fall within the jurisdiction of equity and injunctive relief is therefore unavailable. See Rosen v. Cascade Int'!, Inc., 21 F.3d 1520, 1529-30 (11th Cir. 1994) (holding that the district court Jacked the general equitable authority to issue an

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

the plaintiff seeks only to recover money damages do not fall within the jurisdiction of equity and injunctive relief is therefore unavailable. See Rosen v. Cascade Int'l. Inc. 21 F.3d 1520, 1529-30 (11th Cir. 1994) (holding that the district court lacked the general equitable authority to issue an i

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