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knowledge. The majority of Mr. Cassell's assertions in his affidavit are based on a 2005 Vanity Fair article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair <http://vickyward.com/wordpress/archives/30>, (January 24, 2005; accessed June 24, 2009). Mr.
actually stated "[t]alk that Epstein had moved himself and his assets to Israel reached the ears of such luminaries as Harvey Weinstein .... " See Vicky Ward, "You Will Have Jeffrey Epstein to Kick Around!" Vanity Fair <http://www.vanityfair.com/online/daily/2008/05/vicky-ward-you.html>, (May 7, 2008; ac
st to a defendant of treating his claim of privilege as an admission would be to excuse a plaintiff of presenting proof of his claim; "[ w ]e think Baxter indicates that this is too great a cost"). As Jane Doe fails to present any independent evidence of fraudulent transfer, the Court must deny her re
ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter [v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32
ir article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity F
knowledge. The majority of Mr. Cassell's assertions in his affidavit are based on a 2005 Vanity Fair article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair chttp://vickyward.com/wordpress/archives/30> (January 24, 2005; accessed June 24, 2009). Mr. Cassell
cle (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair c
ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32 (
o is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz has als
afts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz ha
tz stated "I'm on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz has also been quoted as saying that, even if Epstein went bankrupt, "I would be as interested in him as a
is . . . evidence of the most persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S. 149, 153-54 (1923) (Brandeis, J.), quoted in Baxter". Pahnigiano, 425 U.S 308, 319 (1976). And that silence takes on an even more sinister cast when combined with the fact that Epstein's sexual intere
published source of information about defendant Jeffrey Epstein that I have been able to locate is an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vanity Fair, a contributor to CNBC, and a weekly columnist for the London Evening Standard. The article can
an article that was published in Vanity Fair by Vicky Ward. Vicky Ward is a contributing editor to Vani
e to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege." Baxter v. Palmigiano, 425 U.S.308, 335 (1976). An adverse inference is entirely justified in this case. Epstein has remained silent when asked such strai
SCHILLER,RALPH DEWING JR,JOHN P WARD,CHARLES G BENOIT,ELLEN T JAMISON,LE
STA'S RESTAURANT LINGO,BRYCE M HUNT,VICKY U S GOVERNMENT P O MCGANN,KEVIN D
WILLIAM AND MARCIA RICKMAN REVOCABLE TRUST BAXTER,LAURA RUKEYSER,SUSAN C MIKUS,WILLIA
or touching her vagina, inserting his fingers and civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 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 an
Page: HOUSE_OVERSIGHT_010567 →person outside of my immediate family that I send drafts to is Jeffrey” The 29 HOUSE_OVERSIGHT_010594 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit “OO”); (c) Epstein’s housekeeper Alfredo Rodriguez testified that De
Page: HOUSE_OVERSIGHT_010595 →594 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity F
Page: HOUSE_OVERSIGHT_010595 →s not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); Accord, Vasquez v. State, 777 So. 2d 1200, 1203 (Fla. at 2001). The reason for this rule “is both logical an
Page: HOUSE_OVERSIGHT_013315 →347 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity F
Page: HOUSE_OVERSIGHT_013348 →person outside of my immediate family that I send drafts to is Jeffrey” The 29 HOUSE_OVERSIGHT_013347 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit “OO”); (c) Epstein’s housekeeper Alfredo Rodriguez testified that De
Page: HOUSE_OVERSIGHT_013348 →Entities connected to both Vicky Ward and Baxter

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
United States
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Condoleezza Rice
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
Prince Charles
PERSONDoug Band
PERSON
Eric Trump
PERSON
George Mitchell
PERSON