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

solely upon a privileged refusal to admit or deny at the pleading stage.” Epstein Memo. in Opp. [DE 198 at 10] (quoting LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 391 (7th Cir. 1995) (emphasis added)). As just Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 15 of

ase No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Opposition to Jane Doe's Injunction Motion Page 8 of 24 close friends with Prince Andrew and therefore it is reasonable to infer Epstein has international financial contacts (Id. 'l[9); (3) Epstein reportedly limited his clients to those

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

ng the relief sought by Jane Doe based solely on an adverse inference would violate Epstein's Fifth Amendment rights. See LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p

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

nting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p

. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any Epstein owned or c

tations. 145. Phone journal taken from Epstein's home and produced to the FBI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any Epstein owned or controlled aircraft. This is so overbroad that Epstein cannot possibly make a determination as to wh

upon the basis of reliance on Fifth Amendment; there must be other evidence. Baxter v. Pahnigiano, 425 U.S. 308 (1976); Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 924 (7th Cir. 1963) (assertion of Fifth Amendment in an answ