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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
id [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefsbe rg@pod h u rst.com Adam D. Horowitz ahorowit
financial sophistication. See Affidavit of Paul Cassell at ,r 2 Attachment A to this Pleading. 3. Accor
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)
eavily on the affidavit Jane Doe's own counsel. See Affidavit of Paul Cassell, Esq., attached as Exhibit A to the Injunction Motion (DE #165). Mr. Cassell's affidavit is riddled with hearsay, speculation, conjecture and unsupported assumptions and does not contain one material "fact" based on his pers
est 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] Co-counsel for Plain
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)
sel for Plaintiff in Related Case No. 08-80893 ounse or amttj s In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, Paul G. Cassell, Esq. 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. Counsel for Plaintiff in Related Case No. 08-80811 Jack Scarola, Esq. Jac
eavily on the affidavit Jane Doe's own counsel. ate Affidavit of Paul Cassell, Esq., attached as Exhibit A to the Injunction Motion (DE #165). Mr. Cassell's affidavit is riddled with hearsay, speculation, conjecture and unsupported assumptions and does not contain one material "fact" based on his pers
id 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 and utilitarian.
Page: HOUSE_OVERSIGHT_013315 →greed to. represent these girls, along with attorney Jay Howell (an attomey in Jacksonville, Florida with Jay Howell & Associates) and Professor Paul Cassell (a law professor at the University of Utah College Of Law). I filed state court actions on behalf of L.M. and E.W. and a federal court action on beha
Page: HOUSE_OVERSIGHT_013363 →0, along with other attorneys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my thre
Page: HOUSE_OVERSIGHT_013369 →Entities connected to both Palmigiano and Paul Cassell

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSON
United States
LOCATION
Scarlett Johansson
PERSONKatherine W. Ezell
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON