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) facts. Similarly, 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 Eps
erseas with such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein co
solely upon a privileged refusal to admit or deny at the pleading stage.” Epstein Memo. in Opp. [DE 198 at 10] (quoting LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 391 (7th Cir. 1995) (emphasis added)). As just Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 15 of
ho "presumably live(d) as underage prostitutes in condos owned by Epstein" (191 65; see also 62-67); Edwards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to sho
wards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfiel
n for summary judgment." Fid. Funding of Cal., Inc. v. Reinhold, 79 F. Supp. 2d 110, 116 (E.D. N.Y. 1997). As explained in LaSalle Bank Lake View v. Seguban, 54 F. 3d 387, 391 n.7 (7th Cir. 1995): Treating Segubans' silence as a separate piece of evidence supporting the Bank's motion for summary judgme
othing to do with any of his clients or these lawsuits. Q. Which various people? Who? MR. PIKE: Form. THE WITNESS: For example, he tried to depose Bill Clinton, strictly as a means of getting publicity so that he and his firm could fraudulently steal, craft money from unsuspecting investors in South Florid
THE WITNESS: For example, he tried to depose Bill Clinton, strictly as a means of getting publicity so tha
of reliance on Fifth Amendment; there must be other evidence. Baxter, 425 U.S. at 318; Lefkowitz, 431 U.S. at 808, n. 5;Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 924 (7th Cir. 1963) (assertion of Fifth Amendment in an answ
Entities connected to both Bill Clinton and Seguban

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSONJane Doe
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
Vicky Ward
PERSON
Harvey Weinstein
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Paul Ryan
PERSON
Paul Cassell
PERSON
Martha Stewart
PERSON
Bill Richardson
PERSON
Jean-Luc Brunel
PERSONScott Rothstein
PERSON