8
Shared Docs
5
Same-Page
9 / 14
Mentions
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
2 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Oppositio
is . . . evidence of the most persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S. 149, 153-54 (1923) (Brandeis, J.), quoted in Baxter". Pahnigiano, 425 U.S 308, 319 (1976). And that silence takes on an even more sinister cast when combined with the fact that Epstein's sexual intere
UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioner
aid Response be sealed until further order of this Court. DONE AND ORDERED in Chambers at Palm Beach County, Florida, this day of January, 2015. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE EFTA00191401 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE D
tion case, read questions to the jury that my client took the Fifth Amendment to and draw a negative inference therefrom. The US Supreme Court in Baxter -- that's the case -- that's the Fifth Amendment case -- it says, "It's key that there's independent evidence existing of the fact to which the pa
being taken advantage of. Taken advantage of through the forging of an order -- forging of an order that purported to have the signature of Judge Marra -- a tremendously well-respected jurist in this community, now taken senior status. I, meaning Mr. Epstein, was not only concerned about Rothstei
an order that purported to have the signature of Judge Marra -- a tremendously well-respected jurist in this
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
he is transferring them to. Cf. Special Purpose Accounts Receivable Co-op Corp. v. Prime One Capital Co., L.L.C., 2007 WL 4482611 (S.D. Fla. 2007) (Marra, J.) (refusing to 15 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 16 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON
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 (
FFREY EPSTEIN, Defendant. CASE NO.: 08-cv-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOFINSON CA
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 →lved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the fed
Page: HOUSE_OVERSIGHT_013350 →litigation. The RICO claim alleged that Epstein ran an expansive criminal entirpitge that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing ever clients intended to pursue an appeal of that dismi
Page: HOUSE_OVERSIGHT_013350 →at there was some improper coercion involved in, for example, Jane Doe’s case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein sinisly chose to settle that case. He is therefore now barred by the doct
Page: HOUSE_OVERSIGHT_013381 →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 →litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing Edwards' clients intended to pursue an appeal of that d
Page: HOUSE_OVERSIGHT_010597 →lved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the fed
Page: HOUSE_OVERSIGHT_010597 →at there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein simply chose to settle that case. He was therefore barred by the doctrine
Page: HOUSE_OVERSIGHT_029319 →er before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raisi
Page: HOUSE_OVERSIGHT_029319 →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. App. 2001). The reason for this rule "is both logical an
Page: HOUSE_OVERSIGHT_029321 →Entities connected to both Baxter and Kenneth Marra

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Jay Lefkowitz
PERSON
Prince Andrew
PERSONRoy Black
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATIONRobert D. Critton
PERSONMartin Weinberg
PERSON