Epstein Secrets

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

t 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 req

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

equiring 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 (7th Cir. 1983)

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

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 (7th Cir. 1983)

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

id 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 and utilitarian.

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

id 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.

g 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 and utilitarian.

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