120 1 victims’ rights act case that we are talking about is in 2 the Southern District of Florida. I think the record 3 should be clear that that is in the 11th Circuit. And 4 so that case law says that you look at these different 5 factors, one of the factors, that to my mind would weigh 6 heavily in favor of drawing the adverse inference would 7 be the degree of control that the one party has over the 8 other. 9 Dershowitz was the attorney for Epstein and, 10 indeed, we heard today that he continues to be the 11 attorney on the Tri-Tech case and I'm assuming an 12 attorney/client privilege on other matters as well. So 13 he would seem to have a significant control over that. 14 The other thing that was going on in my mind 15 when I'm drawing the adverse inference is that there 16 might be some people that are invoking the Fifth 17 Amendment but not getting sound legal advice. 18 An attorney can only allow his client to 19 assert a Fifth Amendment privilege in civil case if 20 there's a significant risk that the answer will be 21 incriminating. You can't just invoke it willy-nilly. 22 And I knew that Mr. Epstein had been 23 receiving -- you know, as a billionaire would -- you 24 know, the best legal advice that money could buy, and 25 the advice he was getting with regard to questions about ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021943