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, Exhibit "B"; Exhibit "F"; "Exhibit"J"; "N" and See Edwards Affidavit, Exhibit "N" at ¶13. 72. Edwards provided notice that he intended to depose Alan Dershowitz. Edwards possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstein for many years; (b) in one news a
hibit "N" at ¶13. 72. Edwards provided notice that he intended to depose Alan Dershowitz. Edwards possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th book... The only pe
dwards provided notice that he intended to depose Alan Dershowitz. Edwards possessed a legitimate basi
does not forbid adverse inferences against parties to civil actions when they refuse to testify in respqmLwprobative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A pa
l basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Und
of Undisputed Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(iii): With regard to former President Bill Clinton,
uted Facts. • Complaint ¶38(ii): With regard to Alan Dershowitz (Harvard Law Professor), Edwards had
not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian
ivities on EPSTEIN's aircraft (¶ 32(1)); sending letters asking for deposition dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and other individuals who were without any knowledge of relevant eviarnce about EPSTEIN's sex offenses (¶ 32(2)); subp
ment that EPSTEIN abused underage children everywhere, including his airplanes, and that EP' TEIN's pilots and certain other individuals, including Dershowitz, had information relevant to EPSTEIN's repeated abuse of underage girls. mo As yet another example, EPSTEINalleges that EDWARDS had no basis for fi
ion of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and othe
plaintiff's answers can be used against him through adverse inferences. See, e.g , In re J.E.B., 971 So.2d 187, 188 (Fla.App. 2 Dist. 2007) (citing Baxter v. Palmigiano, 425 U.S. 308 (1976) ("[T]he Fifth Amendment does not forbid adverse inferences against parties to civ I actions when they refuse to testify in res
istrict Court, Southern District of Florida Jack Alan Goldberger, Esq. k)Idberger aewpa.com Robert D.
e to permit 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 requ
Entities connected to both Alan Dershowitz and Baxter v. Palmigiano

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONMichael J. Pike
PERSON
Les Wexner
PERSONScott Rothstein
PERSONJack Scarola
PERSON