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hase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR- COHN (S.D. Fla. Jan. 2
Based on this information, Edwards reasonably pursued the flight logs in discovery. 80. In the fall of 2009, Epstein gave a recorded interview to George Rush, a reporter with 29 EFTA00726027 the New York Daily News about pending legal proceedings. In that interview, Epstein demonstrated an utter lack
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
submits this memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to produce a tape recording that news reporter George Rush made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillary discovery proceeding, a civil litigant —
ee of Epstein's victims - "Jane Doe", a." and "E.W."3 B. The Unpublished Epstein Interview George R
unds, 44.3d 324, 843 =2d 218 (1st Dep't 2007) 15 Associated Gen. Contractors of Conn., Inc. v. City of New Haven, 41 F.3d 62 (2d Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Bro
ccident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where
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
Entities connected to both George W. Bush and Baxter v. Palmigiano

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSONJack Goldberger
PERSONMaria Farmer
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONScott Rothstein
PERSON
Vicky Ward
PERSON
Paul Cassell
PERSONJack Scarola
PERSONRobert D. Critton
PERSON
U.S. Virgin Islands
LOCATION