Epstein Secrets

t 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 straightforward req

ument 165 Entered on FLSD Docket 06/19/2009 Page 25 of 41 ward-you.html. According to this note, rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel. The note also indicated that, having

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that

equiring 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 (7th Cir. 1983)

ally, in paragraph 8 of his affidavit, Mr. Cassell cites a May 2008 Vanity Fair article and states "rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel." Id. '1[8 (emphasis added). The arti

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that

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 (7th Cir. 1983)

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that

ally, in paragraph 8 of his affidavit, Mr. Cassell cites a May 2008 Vanity Fair article and states "rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel." Id. 18 (emphasis added). The articl