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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
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 (7th Cir. 1983)
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
t 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 straightforward req
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
equiring 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 (7th Cir. 1983)
g 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 and utilitarian.
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 →id 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 and utilitarian.
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 Palmigiano

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONDoug Band
PERSON
Les Wexner
PERSON
Kenneth Marra
PERSON
Woody Allen
PERSON
Michael Cohen
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSON
Wilbur Ross
PERSONJane Doe
PERSON
Harvey Weinstein
PERSON