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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 (
ro M. Garcia, Esq. Garcia Law Firm, P.A. Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. Bruce Reinhart, Esq. Counsel for Plaintiffs in Related Cases EFTA00221951 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07)
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 →against Epstein contained less detail about sexual abuse than (as one example) a complaint filed by attorney Robert Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit “B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell
Page: HOUSE_OVERSIGHT_010585 →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 →aints against Epstein contained less detail about sexual abuse than (as one aml a complaint filed by attorney Robert Josephsberg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit “B”). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell
Page: HOUSE_OVERSIGHT_013338 →Entities connected to both Baxter and Podhurst Orseck

Jeffrey Epstein
PERSONRobert C. Josefsberg
PERSONJack Goldberger
PERSONJane Doe
PERSONKatherine W. Ezell
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
United States
LOCATION
George W. Bush
PERSONJack Scarola
PERSONRichard Horace Willits
PERSONMichael J. Pike
PERSON
Jay Lefkowitz
PERSONScott Rothstein
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSONIsidro Manuel Garcia
PERSON
Adam D. Horowitz
PERSON
Alan Dershowitz
PERSON