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as alleged that Epstein has international contacts, having travelled overseas with such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these international travels? Here again, it is impossible to tell because Epstein has not explained whether he
ons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these
President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these intern
Do Not Require Independent Evidence Before An Adverse Inference Can Be Drawn Rather than analyze whether the inference satisfies the two-prong Custer Battles test, Epstein pulls another sentence out of context from the opinion, which he claims forms yet a third prong of what Custer Battles itself
tion (discussed below), he frequently traveled around the globe in the company of such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has international contacts, including international financial contacts. See Affidavit of Paul Cassell
President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he has
ons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that
se liberal discovery rules, and 'undermine[s] to some degree the trial system's capacity to ascertain the truth." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 632 (E.D. Va. 2006) (quoting Robert Heidt, The 8 EFTA00234878 Case 9:08-cv-80119-KAM Document 165 Entered on
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ABOUT YOUR ELECTRONIC FUNDS TRANSFERS: Call re at r4,36564.2262 e onto re at Iry address on the from or Ow stericerint (nun prricrolareounts called Custer-or Seto) roma-let* el you the* your statement or receipt inC0rreCt or If you rend mee rqconstion stoat a redneler limes en the steamed o etelpt For
Entities connected to both Donald Trump and Custer

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Prince Charles
PERSON
Woody Allen
PERSON
Samantha Power
PERSON
Wilbur Ross
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONJane Doe
PERSONEmmy Taylor
PERSON