Epstein Secrets

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

must provide some kind of “independent evidence” of his fraudulent transfers in order to gain the inference of fraudulent transfers. The first is Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991), in which Plaintiffs who had filed a frivolous lawsuit appealed from a district court decision grantin

ovided any evidence that the Court should not draw an adverse inference – or, indeed, any evidence at all in opposition to her motion. Accordingly, Avirgan is not on point and certainly does not suggest that Jane Doe needs to provide some sort of independent evidence to obtain an adverse inference.1

t include: (1) Epstein may own a Boeing 727 with a trading room (See Affidavit of Paul Cassell '1[7); (2) Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 8 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Jo

); (2) Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document

Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document 198

lent] billing ... which in tum ensures that the proposed adverse inferences, should the jury choose to draw them, are not unreliable." Id. See also Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991) (holding that "the negative inference to be drawn from the assertion of the fifth amendment does not s

vit include: (1) Epstein may own a Boeing 727 with a trading room (Sec Affidavit of Paul Cassell 17); (2) Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 8 of 24 Jane Doe v. Epstein Case No. 08-CV-808

Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-KAM Do

); (2) Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-K

inferences drawn from Fifth-Amendment-protected silence are treated as a substitute for the need for evidence on an ultimate issue of fact," citing Avirgan, supra). As belabored throughout this memorandum, Jane Doe cites no independent evidence that Epstein is fraudulently transferring assets. Accordi