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Do Not Require Independent Evidence Before An Adverse Inference Can Be Drawn Rather than analyze whether the inference satisfies the two-prong Custer Battles test, Epstein pulls another sentence out of context from the opinion, which he claims forms yet a third prong of what Custer Battles itself
of a receiver to take charge of Epstein’s property and to post a $15 million bond to secure any potential judgment in this case. As explained in Jane Doe’s motion, Epstein is a billionaire who recently has been fraudulently transferring his assets overseas and elsewhere with the intent to prevent Jane D
ether the Fifth Amendment privilege is validly asserted in response to particular questions. This issue is typically resolved on a motion to compel. Custer Battles 415 F. Supp. 2d at 633. If it is determined that the privilege is properly asserted, then adverse inferences are admissible consistent with
Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do
ether the Fifth Amendment privilege is validly asserted in response to particular questions. This issue is typically resolved on a motion to compel. Custer Battles 415 F. Supp. 2d at 633. If it is determined that the privilege is properly asserted, then adverse inferences are admissible consistent with
Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do
se liberal discovery rules, and 'undermine[s] to some degree the trial system's capacity to ascertain the truth." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 632 (E.D. Va. 2006) (quoting Robert Heidt, The 8 EFTA00234878 Case 9:08-cv-80119-KAM Document 165 Entered on
iff vs. JEFFREY EPSTEIN, Defendant JANE DOE NO. 102, CASE NO: 09-CV-80656-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15
Entities connected to both Custer and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSONSouthern District
LOCATION
Salt Lake City
LOCATIONRobert C. Josefsberg
PERSONRichard Horace Willits
PERSON
Prince Andrew
PERSONJack Patrick Hill
PERSON