Parker v. U.S. Attorney General

District Court, S.D. Florida·Decided May 6, 2025·No. 1:23-cv-21388·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 23-cv-21388-BLOOM/TORRES EMILE PARKER,

Petitioner, v. U.S. ATTORNEY GENERAL,

Respondent. ___________________________________________/ ORDER ON MOTION IN LIMINE FOR ADVERSE INFERENCES

This cause comes before the Court on Respondent, the U.S. Attorney General’s Motion to draw certain adverse inferences against Petitioner, Emile Parker. [D.E. 63]. Petitioner has responded to the Motion, to which Respondent has replied. The Motion, therefore, is ripe for disposition.1 After careful review of the briefing, pertinent portions of the record, and relevant authorities, and for the reasons set forth below, Respondent’s Motion is GRANTED.

1 On April 9, 2025, the Honorable Beth Bloom referred this matter to the Undersigned Magistrate Judge for disposition. [D.E. 86]. I. BACKGROUND Throughout this case, Petitioner has stonewalled discovery. As the Court detailed in its Discovery Order, Petitioner’s non-participation has included: a

“refusa[al] to answer a significant number of questions at his October 11, 2023 deposition” under a purported Fifth Amendment privilege; “insufficient” responses to interrogatories (in which he incorporated by reference his Fifth Amendment assertions at his deposition); initial disclosures that “were insufficient given the over- broad categorization of the types of evidence Petitioner intended to rely upon”; a “refusal to provide responsive documents”; and an inadequate response to requests

for admissions. [D.E. 58 at 4–6]. Consequently, this Court concluded that “Petitioner is precluded from offering witness testimony, declarations, or other documentary evidence in summary judgment briefing and/or at trial.” [Id. at 7]. This Court also found that “Respondent is entitled to certain adverse inferences to be drawn against Petitioner.” [Id.]. This Court then required Respondent to file supplemental briefing (i.e., this Motion) to request those adverse inferences.

In the pending Motion, Respondent has requested a variety of adverse inferences which purportedly are necessitated by Petitioner’s widespread failure to participate in discovery. Petitioner, meanwhile, argues that despite the Court’s Discovery Order, “Petitioner’s invocation of his Fifth Amendment right was justified” and therefore Respondent must find a different way to navigate Petitioner’s discovery shortfalls. [D.E. 73 at 1]. II. ANALYSIS The Eleventh Circuit “has held … that the trier of fact may take an adverse inference against the parties to a civil action refusing to testify on Fifth Amendment

grounds.” United States v. Two Parcels of Real Prop. Located in Russell Cnty., Ala., 92 F.3d 1123, 1129 (11th Cir. 1996) (citing United States v. A Single Family Residence, 803 F.2d 625, 629 n.4 (11th Cir. 1986)). Indeed, “[t]he decision to invoke the Fifth Amendment does not have to be consequence-free.” Eagle Hosp. Physicians, LLC v. SRG Consulting, Inc., 561 F.3d 1298, 1304 (11th Cir. 2009) (citing United States v. White, 589 F.2d 1283, 1287 (5th Cir. 1979)). “Courts may not draw adverse

inferences, however, if it is the sole basis for [p]laintiff's prima facie case, or will cause the ‘automatic entry of summary judgment.’” F.T.C. v. Glob. Mktg. Grp., Inc., 594 F. Supp. 2d 1281, 1287 (M.D. Fla. 2008) (quoting F.T.C. v. Transnet Wireless Corp., 506 F.Supp.2d 1247, 1252 (S.D. Fla. 2007)). Here, Respondent seeks a plethora of adverse inferences based on Petitioner’s refusal to answer deposition questions or respond to discovery concerning his nationality claim. As a result, Respondent asserts that it lacks critical information

“on topics ranging from general biographical information to questions about Petitioner’s travel history and connections with his alleged father.” [D.E. 63 at 7]. Petitioner, meanwhile, asserts three broad defenses in addition to his defenses against each adverse inference. As to the first broad defense, Petitioner argues that he had no choice but to assert his privilege because he feared criminal prosecution. As to the second, Petitioner contends that permitting adverse inferences would effectively result in an automatic judgment against Petitioner. And third, Petitioner asserts the unfair prejudice occasioned by the inferences would overwhelmingly outweigh the probative value.

A. Petitioner’s Broad Objections We will first address Petitioner’s broad objections: that he feared criminal prosecution, that the inferences would result in an automatic judgment due to a lack of corroborating evidence, and that any probative value is substantially outweighed by unfair prejudice.2 1. Criminal Prosecution Objection

As to Petitioner’s initial objection, we have no grounds to doubt the veracity of Petitioner’s subjective belief that he invoked his Fifth Amendment privilege because he feared prosecution. But that subjective belief does not sway our analysis. We have absolutely no evidence on the record to suggest that Petitioner’s fear was so legitimate and so reasonable as to justify an absolute stonewalling of discovery. Nor does Petitioner provide any factual or legal support whatsoever to support this conclusory objection. Rather, Petitioner effectively urges us to take his word for it that he was

justified in declining to produce any discovery or answer any deposition questions relevant to his nationality claim.

2 The Court already held at the parties’ discovery hearing that Respondent is entitled to draw certain adverse inferences; this briefing was ordered to serve as a supplement for what adverse inferences were in order, not whether adverse inferences were in order. Petitioner’s proper recourse to challenge Respondent’s entitlement to adverse inferences would have been a motion for rehearing or reconsideration. Nonetheless, in an abundance of caution, we will still fully consider Petitioner’s arguments as to entitlement. That we will not do. See Hoffman v. United States, 341 U.S. 479, 486 (1951) (“The witness is not exonerated from answering merely because he declares that in so doing he would incriminate himself—his say-so does not of itself establish the

hazard of incrimination.”). Petitioner continuously asserted his Fifth Amendment privilege with no explanation whatsoever, refused to answer hardly any questions, and incorporated that unresponsiveness into his discovery responses. Consequently, Respondent faces enormous prejudice in that it cannot gather any useful information to lodge a defense against Petitioner’s nationality argument. Accordingly, Petitioner’s unsubstantiated objection that no adverse inferences should be permitted is wholly

without merit. See State Farm Mut. Auto. Ins. Co. v. Filenger, 362 F. Supp. 3d 1246, 1255 (S.D. Fla. 2018) (drawing adverse inferences because “in their responses to interrogatories and in response to Plaintiffs' complaint, Filenger, Greydinger, Rubinshteyn, and Varisco all invoked their Fifth Amendment privilege against self- incrimination” and provided no justification); Sec. & Exch. Comm'n v. Calmes, No. 09-80524-CIV, 2010 WL 11505260, at *3 (S.D. Fla. Nov.

Free access — add to your briefcase to read the full text and ask questions with AI

Parker v. U.S. Attorney General, (S.D. Fla. 2025).

Parker v. U.S. Attorney General (Parker v. U.S. Attorney General) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Eagle Hospital Physicians, LLC v. SRG Consulting, Inc.
561 F.3d 1298 (Eleventh Circuit, 2009)
Hoffman v. United States
341 U.S. 479 (Supreme Court, 1951)
United States v. William D. White and Terry L. Keno
589 F.2d 1283 (Fifth Circuit, 1979)
Nationwide Life Insurance v. Richards
541 F.3d 903 (Ninth Circuit, 2008)
Federal Trade Commission v. Transnet Wireless Corp.
506 F. Supp. 2d 1247 (S.D. Florida, 2007)
Federal Trade Commission v. Global Marketing Group, Inc.
594 F. Supp. 2d 1281 (M.D. Florida, 2008)
Securities & Exchange Commission v. Monterosso
746 F. Supp. 2d 1253 (S.D. Florida, 2010)
State Farm Mut. Auto. Ins. Co. v. Filenger
362 F. Supp. 3d 1246 (S.D. Florida, 2018)
United States v. A Single Family Residence
803 F.2d 625 (Eleventh Circuit, 1986)
United States v. Premises Located at Route 13
946 F.2d 749 (Eleventh Circuit, 1991)