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s is based on inadmissible hearsay newspaper reports, Wikipedia, and the 2005 Vanity Fair Article. Mr. Cassell asserts that Epstein's "real mentor [Steven Hoffenberg] was sent to federal prison for twenty years for bilking investors out of more than $450 million on one of the largest Ponzi schemes in American hi
a Ponzi scheme. The 2005 Vanity Fair Article reports on Epstein's business dealings with Steven Hoffenberg during the 1980's and merely notes that Hoffenberg is "currently ... serving a 20-year sentence" for operating a Ponzi scheme. Importantly, despite all the questionable and speculative suggestions a
st to a defendant of treating his claim of privilege as an admission would be to excuse a plaintiff of presenting proof of his claim; "[ w ]e think Baxter indicates that this is too great a cost"). As Jane Doe fails to present any independent evidence of fraudulent transfer, the Court must deny her re
ge without 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
financial instruments and other assets. 5. According to the Vanity Fair article, defendant Jeffrey Epstein's real mentor was not Leslie Wexner, but Steven Jude Hoffenberg, who was sent to federal prison for twenty years for bilking investors out of more than $450 million in one of the largest Ponzi schemes in America
ison for twenty years for bilking investors out of more than $450 million in one of the largest Ponzi schemes in American history. Epstein assisted Hoffenberg with (failed) takeover bids of Pan American World Airways and Emery Air Freight. 6. According to the Vanity Fair article, before working with Wexne
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 strai
s is based on inadmissible hearsay newspaper reports, Wikipedia, and the 2005 Vanity Fair Article. Mr. Cassell asserts that Epstein's "real mentor [Steven Hoffenberg] was sent to federal prison for twenty years for bilking investors out of more than $450 million on one of the largest Ponzi schemes in American hi
a Ponzi scheme. The 2005 Vanity Fair Article reports on Epstein's business dealings with Steven Hoffenberg during the 1980's and merely notes that Hoffenberg is "currently ... serving a 20-year sentence" for operating a Ponzi scheme. Importantly, despite all the questionable and speculative suggestions a
ge without 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 (
Entities connected to both Steven Hoffenberg and Baxter

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSON
Les Wexner
PERSON
Donald Trump
PERSON
Marc Rich
PERSON
Vicky Ward
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Martha Stewart
PERSON
Bear Stearns
ORGANIZATION
Virginia Giuffre
PERSON
Melinda Gates
PERSON
Alfredo Rodriguez
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON