Epstein Secrets

the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production")• Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th

in Opposition to Jane Doe's Injunction Motion Page 22 of 24 V. CONCLUSION For the foregoing reasons, Epstein respectfully requests the Court deny Jane Doe's Injunction Motion. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 DAVID A. YAREMA, ESQ. Flo

ane Doe's Request for Admissions attached as Exhibit C to Injunction Motion (DE #165). Based on this unsupported presumption of fraudulent transfer, Jane Doe asks the Court to impose significant and unjustified restraints on Epstein's assets. Simply put, Jane Doe is improperly seeking assurance she will b

rse inference would be wholly unreliable and is clearly impermissible under the instant circumstances. Additionally, granting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir.

the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production"); Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th

e's Injunction Motion Page 5 of24 relief requested by Jane Doe. For the following reasons, the Court must deny Jane Doe's Injunction Motion. II. JANE DOE'S STATEMENT OF MATERIAL FACTS IS BASED ON SPECULATION AND HEARSAY AND CONTAINS NO MATERIAL "FACTS" Jane Doe's "Statement of Material Facts" relies h

JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. I EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO 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 $1

o provide some sort of independent evidence to obtain an adverse inference.1 The other case cited by Epstein -- Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) -- is likewise unavailing. There, a defendant presented an affidavit to the district court that attached attorney-

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

the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production"); Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where t

nd that she had to see a therapist in Miami at her attorney's request and fake cry, pretend like she was damaged and pretend she had been molested; Jane Doe No. 7 was laughing about it. Id. at 264; h. Jane Doe No. 7 never complained that Epstein acted inappropriately or that she suffered any emotional

. 19 E & J Gallo Winery v. Encana Energy Servs.. Inc.. 33 Media L. Rep. 1413 (S.D.N.Y. 2004) 2 iii EFTA00207334 Eagle Hosp. Physicians. LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) 7 Gonzales v. National Broad. Co., 194 F.3d 29 (2d Cir. 1999) 2, 3 Hill v. Federal Trade Comm'n, 124 F.2d 104

im to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carroll Reply Dec1.1 6). Further bolstering Doe's claims in the underlying case is the fact that evidence of sexual abu