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841, 842 (Fla. 4" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumskyp 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: e 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. e 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. 7 e 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. e Question not answered: “How many minors have you procured for prostitution?” Reasonable inference: Epstein has procured multiple minors for prostitution. e 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.?”

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