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

dant’s] seemingly blanket invocation of the privilege against self-incrimination.” Custer Battles, 41 F.Supp.2d at 634-35 (emphasis added). Thus, Custer Battles cautioned against drawing inferences about other people’s state of mind via an adverse inference from defendant Morris’ invocation of his Fifth Amen

such an inference is somehow not proper under the test laid out by United States v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). Custer Battles lays out a two-prong test for deciding whether a factfinder can appropriately draw an adverse inference. The first prong is whether there is “a vali

tein Case No. 08-CV-80893-Marratlohnson Epstein's Memorandum of taw in Opposition to Jane Doe's In/unction Motion Page 8 of 24 close friends with Prince Andrew and therefore it is reasonable to infer Epstein has international financial contacts ULL 19); (3) Epstein reportedly limited his clients to those w

n Motion Page 8 of 24 close friends with Prince Andrew and therefore it is reasonable to infer Epstein h

ly be drawn when independent evidence exists of the fact to which the party refuses to answer." Id. at 635 (emphasis added) (citations omitted). In Custer Battles. LLC unlike the instant case, the court found the record contained "ample evidence of Morris' involvement in the [fraudulent) billing ... which in

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

lege without placing the witness in the 'cruel trilemma' of choosing among incrimination, perjury, or contempt." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from