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inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps
After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le
entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have
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
LING PALM BEACH LLC OTTO,JONATHAN B MAXWELL,GERTRUDE COLEMAN,CATHERINE FISHER,K
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 →f Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit “B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein we
Page: HOUSE_OVERSIGHT_010585 →“B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world. According to the Compla
Page: HOUSE_OVERSIGHT_010585 →s personal pilot), Larry Harrison (Epstein’s personal pilot), Louella Rabuyo (Epstein’s housekeeper), Nadia Marcinkova (Epstein’s live-in sex slave), Ghislaine Maxwell (manager of Epstein’s affairs and businesses), Mark Epstein (Epstein’s brother), and Janusz Banasiak (Epstein’s house manager) It was nearly i
Page: HOUSE_OVERSIGHT_010592 →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 →f Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit “B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein we
Page: HOUSE_OVERSIGHT_013338 →“B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein’s house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world. According to the Compla
Page: HOUSE_OVERSIGHT_013338 →s personal pilot), Larry Harrison (Epstein’s personal pilot), Louella Rabuyo (Epstein’s housekeeper), Nadia Marcinkova (Epstein’s live-in sex slave), Ghislaine Maxwell (manager of Epstein’s affairs and businesses), Mark Epstein (Epstein’s brother), and Fane Banasiak (Epstein’s house manager) It was nearly im
Page: HOUSE_OVERSIGHT_013345 →Entities connected to both Ghislaine Maxwell and Baxter

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONDoug Band
PERSONFBI
ORGANIZATION