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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
the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production"); Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th
, 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
o provide some sort of independent evidence to obtain an adverse inference.1 The other case cited by Epstein -- Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) -- is likewise unavailing. There, a defendant presented an affidavit to the district court that attached attorney-
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
the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production")• Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th
Entities connected to both Prince Andrew and SRG Consulting, Inc.

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
George W. Bush
PERSON
Martha Stewart
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Harvey Weinstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Vicky Ward
PERSON
Bradley Cooper
PERSON
James Baker
PERSON
Bear Stearns
ORGANIZATION
Bernie Sanders
PERSON
Sarah Kellen
PERSONScott Rothstein
PERSON