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ut the complained-of conduct.” Special Purpose Accounts Receivable Co-op Corp. v. Prime One Capital Co., .L.L.C, 2007 WL 4482611 (S.D. Fla. 2007) (Marra, J.). Obtaining information about the whereabouts of Epstein’s assets is particularly difficult, given his financial sophistication in structurin
o provide some sort of independent evidence to obtain an adverse inference.1 The other case cited by Epstein -- Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298 (11th Cir. 2009) -- is likewise unavailing. There, a defendant presented an affidavit to the district court that attached attorney-
2 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Oppositio
the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production"); Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th
FFREY EPSTEIN, Defendant. CASE NO.: 08-cv-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOFINSON CA
the assertion of the fifth amendment does not substitute for evidence needed to meet the burden of production")• Eagle Hospital Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (recognizing that "dismissal following the assertion of the Fifth Amendment violates the Constitution where th
Entities connected to both Kenneth Marra and SRG Consulting, Inc.

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSONMichael J. Pike
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATIONScott Rothstein
PERSON
Adam D. Horowitz
PERSON
Southern District of New York
ORGANIZATION
Sarah Kellen
PERSONJack Scarola
PERSON
Julie K. Brown
PERSON
New York
LOCATION