Epstein Secrets

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

st to a defendant of treating his claim of privilege as an admission would be to excuse a plaintiff of presenting proof of his claim; "[ w ]e think Baxter indicates that this is too great a cost"). As Jane Doe fails to present any independent evidence of fraudulent transfer, the Court must deny her re

ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter [v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32

we see. We see many different things that happened. So, for example, all of a sudden you have Mr. Edwards and his team saying they want to depose Donald Trump, Bill Clinton. And there wasn't any testimony from the three folks that Mr. Edwards represented DRAFT ONLY !!!! NOT PROOFREAD EFTA00792836 27

6 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that they had any contact with Mr. Clinton or Mr. Trump, or any of the other folks that they said they wanted to depose. The three folks that Mr. Edwards represented never said they were on one of Mr.

Edwards and his team saying they want to depose Donald Trump, Bill Clinton. And there wasn't any testim

5 that they had any contact with Mr. Clinton or Mr. Trump, or any of the other folks that they said they w

tion case, read questions to the jury that my client took the Fifth Amendment to and draw a negative inference therefrom. The US Supreme Court in Baxter -- that's the case -- that's the Fifth Amendment case -- it says, "It's key that there's independent evidence existing of the fact to which the pa

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

ons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that

President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to infer that he ha

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 strai

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

ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32 (

PETER D WINCHESTER,VALERIE J MARRON,DONALD B MARKIN,SUSAN C NANETTE KASS RESIDEN

SCARPA,JOHN F COOLEY,WILLIAM O TRUMP,IVANA WAGNER,JOE GREENS PHARMACY

WILLIAM AND MARCIA RICKMAN REVOCABLE TRUST BAXTER,LAURA RUKEYSER,SUSAN C MIKUS,WILLIA

fact that I notified him that I intended to take Donald Trump’s deposition in the civil suits against him. Trump

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

he deposition of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads eaifisnated 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 Edwards’s clients’ complaints; (b) Trump was

uted facts show the following with regard to each of the persons identified in Epstein's complaint of improper targets of discovery: • With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts filed in support

ns identified in Epstein's complaint of improper targets of discovery: • With regard to Donald Trump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts filed in support of Edwards' Motion for Summary Judgment. • With regard

rump, Edwards had sound legal basis for believing Mr. Trump had relevant and discoverable information. See St

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. App. 2001). The reason for this rule "is both logical an

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

had “no connection 9 HOUSE_OVERSIGHT_010574 --- PAGE BREAK --- whatsoever” with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 (Bill Clinton phone numbers listed under “Doug Bands”). ‘E ederal Investigation and Plea Agreement With Epstein 19. In approximately 2005, th

he 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 Edwards’s clients’ complaints; (b) Trump was