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people that Epstein alleges in his Complaint had "no connection whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton phone numbers listed under "Doug Bands"). Federal Investigation and Plea ARreement With Epstein 19. In app
deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my clients' complaints; (b) Trump was quoted
this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 8 EFTA00726006 (Bill Clinton pho
ed that Jane Doe 102 was initially approached at Trump's Maralago by Ohislaine Maxwell and recruited to be
does not forbid adverse inferences against parties to civil actions when they refuse to testify in respqmLwprobative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A pa
tion. The undisputed facts show the following with regard to each of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint
ach of the persons raised in Epstein's complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Pro
s complaint: • Complaint ¶38(i): With regard to Donald Trump, Edwards had sound legal basis for believi
ump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See St
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. App. 2001). The reason for this rule "is both logical and utilitarian
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
e to permit 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 requ
jet pilots about sexual activities on EPSTEIN's aircraft (¶ 32(1)); sending letters asking for deposition dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and other individuals who were without any knowledge of relevant eviarnce about EPSTEIN
dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David C
sition dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician D
plaintiff's answers can be used against him through adverse inferences. See, e.g , In re J.E.B., 971 So.2d 187, 188 (Fla.App. 2 Dist. 2007) (citing Baxter v. Palmigiano, 425 U.S. 308 (1976) ("[T]he Fifth Amendment does not forbid adverse inferences against parties to civ I actions when they refuse to testify in res
Entities connected to both Donald Trump and Baxter v. Palmigiano

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Bradley Edwards
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONJane Doe
PERSONthe Southern District
LOCATION
Les Wexner
PERSON
Bill Richardson
PERSON
Vicky Ward
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
Paul Cassell
PERSON
U.S. Virgin Islands
LOCATION