Epstein Secrets

, Jane Doe has 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 ex

th such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that h

Do Not Require Independent Evidence Before An Adverse Inference Can Be Drawn Rather than analyze whether the inference satisfies the two-prong Custer Battles test, Epstein pulls another sentence out of context from the opinion, which he claims forms yet a third prong of what Custer Battles itself

orts, Jeffrey Epstein has travelled internationally with Donald Trump, former President Bill Clinton, and Prince Andrew. See, e.g., The Daily Mail, Prince Andrew's Billionaire Friend is Accused of Preying on Girl of 14, Apr. 29, 2007, http://www.dailyznail.co.uldnews/article- 451372/Prince-Andrews-billionaire-f

famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable to

se liberal discovery rules, and 'undermine[s] to some degree the trial system's capacity to ascertain the truth." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 632 (E.D. Va. 2006) (quoting Robert Heidt, The 8 EFTA00234878 Case 9:08-cv-80119-KAM Document 165 Entered on

tt, John Maxon, Joe Salamone. Randy Grovenstien, Andrew Malluck John Louis, Michael Brinley From: Charl

0000 a:-.0a. Stritini • 834113. X (901010 EFTA_R1_00013087 EFTA01734700 II EFTA_R1_00013088 EFTA01734701 680V.000—L8—Vid3 G550 SN 5176 Custer' GC576015260 Augum 15.2007 Rev A Seco 122007 Revisions Rev Data A 12-Sao-07 Added Mtwara per VVCR 5176.2 20-Nov-07 20-Nov-07 A A A Arm