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nt incarceration (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 Affidav
f such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. It is therefore reasonable t
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
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
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)
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
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)
Entities connected to both Prince Andrew and Palmigiano

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSONSouthern District
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Michael Cohen
PERSON
Woody Allen
PERSON
Martha Stewart
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Michael Jackson
PERSONFBI
ORGANIZATION
Harvey Weinstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON