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of 40 EXHIBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of I
02 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage
lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it — Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like L
ies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
mmediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Pahnigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitaria
IN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017 AFFIDAVIT OF JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVE
JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVERY WAS WITHHELD UNDER CLAIMS OF PRIVILEGE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Response to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Motion in Limine
DICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.
millions of dollars. Q. And trying to find out, Mr. Epstein, whether you have any evidence whatsoever that
and 6 generate cases. See Deposition of Jeffi•ey Epstein, p. 28; line13-p. 29; line 6. BY MR. SCAROLA: Q
o testify in response to probative evidence offered against them...." Fraser v. Sec. & Inv. Corp., 615 So. 2d 841, 842 (Fla. 4th DCA 1993) (quoting Baxter v. Pahnigiano, 425 U.S. 308, 96 S. Ct. 1551, 47 L. Ed. 2d 810 (1976)(emphasis added)). Accordingly, the evidence in which the party is refusing to testify to mus
dant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Orde
er-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") a
OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOT
laintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his l
his litigation. See Deposition Transcript of Jef•ey Epstein. When Edwards's inquiry turned to questions rega
" Finally, the law is clear that a party cannot be found liable solely upon the basis of reliance on Fifth Amendment; there must be other evidence. Baxter v. Pahnigiano, 425 U.S. 308 (1976); Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 924
Entities connected to both Jeffrey Epstein and Baxter v. Pahnigiano
Larry Visoski
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSON
Jean-Luc Brunel
PERSON
Alfredo Rodriguez
PERSON
Bill Clinton
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Bill Richardson
PERSON
Jay Lefkowitz
PERSONScott Rothstein
PERSON
Paul Ryan
PERSONJack Scarola
PERSONTommy Mottola
PERSON