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Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 14 of 21 Seguban, 54 F.3d 387, 391 (7th Cir.1995); Peiffer v. Lebanon Sch. Dist., 848 F.2d 44, 46 (3d Cir.1988). Thus, silence can only result in any inference when it “is countered by independent evidence of the fact being questioned, but that same inference cannot be drawn when, for example, silence is the answer to an allegation contained in a complaint.” Doe ex rel. Rudy- Glanzer, 232 F.3d at 1264 (citing Nat'l Acceptance Co. v. Bathalter, 705 F.2d 924, 930 (7th Cir.1983). “In such instances, when there is no corroborating evidence to support the fact under inquiry, the proponent of the fact must come forward with evidence to support the allegation, otherwise no negative inference will be permitted.” Jd. (citing LaSalle Bank, 54 F.3d at 391); see also OS Recovery, Inc. v. One Groupe Int'l, Inc., No. 02 CIV. 8993LAK, 2005 WL 850830, at *1 (S.D.N.Y. Apr. 13, 2005) (“inference from invocation of the privilege may be appropriate only where there is independent evidence corroborating the proposition sought to be inferred’’). Here, the vast majority of questions posed to Mr. Epstein lack any foundation or corroboration other than being allegations and assertions of the Plaintiff in this matter. It is Plaintiff's burden to come forward with independent corroborating evidence for each question posed to Mr. Epstein before the court can even consider allowing presentation of the questions and invocation to a jury. Plaintiff's complete failure to provide such evidence for the designated testimony requires that it be excluded from trial. 7. HE «2s 2 witness in the investigation and indictment of Jeffrey Epstein in 2006. She very clearly testified in her deposition in this matter that she has little or no memory of most or all of the events surrounding the time she knew Mr. Epstein, and specifically testified that she is in therapy for the purpose of repressing any memories concerning Mr. Epstein. See Menninger Decl. Ex. D 8:8-9:7; 57:16-58:25. As such, the vast majority of her testimony is that she has no present recollection of events so that she cannot respond to the questions posed to her. 12