841, 842 (Fla. 4"" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S
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841, 842 (Fla. 4"" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S.
149, 153-154 (1923) (Brandeis, J.).
In the circumstances of this case, a reasonable finder of fact would have “evidence of the
most persuasive character” from Epstein’s repeated refusal to answer questions propounded to
him. To provide but a few examples, here are questions that Epstein refused to answer and the
reasonable inference that a reasonable finder of fact would draw:
Question not answered: “Specifically what are the allegations against you which
you contend Mr. Edwards ginned up?” Reasonable inference: No allegations
against Epstein were ginned up.
Question not answered: “Well, which of Mr. Edwards’ cases do you contend
were fabricated?” Reasonable inference: No cases filed by Edwards against
Epstein were fabricated.
Question not answered: “Did sexual assaults ever take place on a private airplane
on which you were a passenger?” Reasonable inference: Epstein was on a private
airplane while sexual assaults were taking place.
Question not answered: “How many minors have you procured for prostitution?”
Reasonable inference: Epstein has procured multiple minors for prostitution.
Question not answered: “Is there anything in L.M.’s Complaint that was filed
against you in September of 2008 which you contend to be false?” Reasonable
inference: Nothing in L.M.’s complaint filed in September of 2008 was false —
ie., as alleged in L.M.’s complaint, Epstein repeatedly sexually assaulted her
while she was a minor and she was entitled to substantial compensatory and
punitive damages as a result.
Question not answered: “I would like to know whether you ever had any physical
contact with the person referred to as Jane Doe in that [federal] complaint?”
Reasonable inference: Epstein had physical contact with minor Jane Doe as
alleged in her federal complaint.
Question not answered: “Did you ever have any physical contact with E.W.?”
Reasonable inference: Epstein had physical contact with minor E.W. as alleged in
her complaint.
Question not answered: “What is the actual value that you contend the claim of
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