Epstein Secrets

633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence. For example, in United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996), the district court drew an adverse inference when claimants to real property r

tions. Thus, there is a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). Th

ates District Court, Southern District of Florida Jack Alan Goldberger, Esq. k)Idberger aewpa.com Robert D. Critton, Esq. rcritton(&.bciclaw.com Isidro Manual Garcia isidrociarcia bellsouth.net Jack Patrick Hill inhesearcvlaw.com Katherine Warthen Ezell KEzella,podhurst.com Michael James Pike MPikeebelclaw.

bly calculated to lead to the discovery of admissible evidence. 8. Describe, with specificity, your travel to locations outside the 50 states of the United States in 2005, 2006, 2007, and 2008, including your dates of travel, location to which you traveled and persons that accompanied you in each such travel.

District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike MPike@bclc

bly calculated to lead to the discovery of admissible evidence. 8. Describe, with specificity, your travel to locations outside the 50 states of the United States in 2005, 2006, 2007, and 2008, including your dates of travel, location to which you traveled and persons that accompanied you in each such travel.

District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike MPike@bclc

effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, woul

tates District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected]

sexual assault" as any "crime under Federal law or the law of a State . . . that involved . . . any conduct proscribed by chapter 109A of title 18, United States Code" - i.e., federal sex offenses against children. Fed. R. Evid. 413(d). Jane Doe's First Amended Complaint alleges that Epstein committed many su

tates District Court, Southern District of Florida Jack Alan Goldberger, Esq. Jooldberaeraaawpa.com Robert D. Critton, Esq. [email protected] Isidro Manual Garcia [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] 19 EFTA00222666