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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
suits filed against you. RFA's #6. • You are moving significant financial assets overseas, outside of the direct territorial reach of the U.S. and Florida Courts. RFA's #21. • You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases. RFA
ht to °Hectare remirientaben Ai:con:Jingly. I assert my *decal constitutional regnts under :- 113 Sulh. arc Fotifleen6sAinendrnems as guaranteed by the united States Constitution Drawls° an adverse inference under these carrumstances would unconshtiaionally burden my exercise OI my nyeblimenal rights. would be
y Florida Statutes C Sermal Battery 7I You are moving Hgnificant financial assets Overseas. outside of the direct fernforre rearri of Me It S and Florida Courts 22 You are maxim asset transfers with the intent to defeat any judgment that mot be entre° against yOu in this or smiler cases 73 You currently h
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
ate property in foreign countries. • You are moving significant financial assets overseas, outside of the direct territorial reach of the U.S. and Florida Courts. • You currently have the ability to post a bond of $15 million to satisfy a judgment in this case without financial or other difficulty. In respo
Entities connected to both United States and Florida Courts

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONSouthern District
LOCATION
Paul Cassell
PERSON
Vicky Ward
PERSON
United States District Court
ORGANIZATIONRobert C. Josefsberg
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONRichard Horace Willits
PERSONJANE DOE NO.
PERSONStuart S. Mermelstein
PERSONJack Patrick Hill
PERSON