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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
Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 [email protected] [email protected] Counsel for Plaintiff, C.M.A. Bruce Reinhart, Esq. Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected]
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 (
24 jaw Doe v. Eosteth Case No. 08-CV-80893-Marra/Johnson Epstein's Manorandwn of Law in Opposition to Jane Doe's Injunction Motion Page 24 of 24 Bruce E. Reinhart, P.A. ounse or ►e t 'ri Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leo ' .ld, P.A. ounse 08-08804 or awl in •e ate. Case
or touching her vagina, inserting his fingers and civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule “is both logical an
Page: HOUSE_OVERSIGHT_010567 →st one of the complaints against Epstein for her role in bringing girls to Epstein’s mansion to be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on 22 HOUSE_OVERSIGHT_010587 --- PAGE BREAK --- all substantive questions regarding her role in arranging for minor girls t
Page: HOUSE_OVERSIGHT_010588 →s not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); Accord, Vasquez v. State, 777 So. 2d 1200, 1203 (Fla. at 2001). The reason for this rule “is both logical an
Page: HOUSE_OVERSIGHT_013315 →st one of the complaints against Epstein for her role in bringing girls to Epstein’s mansion to be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on 22 HOUSE_OVERSIGHT_013340 --- PAGE BREAK --- all substantive questions regarding her role in arranging for minor girls t
Page: HOUSE_OVERSIGHT_013341 →Entities connected to both Baxter and Bruce E. Reinhart

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Scarola
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSON
Sarah Kellen
PERSONMichael J. Pike
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSONSpencer Kuvin
PERSONScott Rothstein
PERSON
Kenneth Marra
PERSON
Adam D. Horowitz
PERSON
Salt Lake City
LOCATIONRobert D. Critton
PERSON
Alan Dershowitz
PERSON