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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
solely upon a privileged refusal to admit or deny at the pleading stage.” Epstein Memo. in Opp. [DE 198 at 10] (quoting LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 391 (7th Cir. 1995) (emphasis added)). As just Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 15 of
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
ng the relief sought by Jane Doe based solely on an adverse inference would violate Epstein's Fifth Amendment rights. See LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p
not "to ascertain the facts and fairly present [Edwards'] defenses." Id. 6 For example, Edwards' counsel asked Plaintiff whether he socialized with Donald Trump in the presence of women under the age of 18. Plaintiff responded by invoking his right against self-incrimination. (Plaintiff at 89). Plaintiff a
he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for depos
to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for
n for summary judgment." Fid. Funding of Cal., Inc. v. Reinhold, 79 F. Supp. 2d 110, 116 (E.D. N.Y. 1997). As explained in LaSalle Bank Lake View v. Seguban, 54 F. 3d 387, 391 n.7 (7th Cir. 1995): Treating Segubans' silence as a separate piece of evidence supporting the Bank's motion for summary judgme
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
nting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p
Entities connected to both Donald Trump and Seguban

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONJane Doe
PERSON
Harvey Weinstein
PERSON
Paul Ryan
PERSONthe Southern District
LOCATION
Bill Richardson
PERSON
Kenneth Marra
PERSON
Vicky Ward
PERSON
Martha Stewart
PERSON
Rudy Giuliani
PERSON
James Baker
PERSONScott Rothstein
PERSON