needed to make a
reasonable showing that El is entitled to punitive damages. See Avirgan v. Hull, 932
F.2d 1572, 1580 (11th Cir. 1991) (holding that "the negative inference ... substitute for the need for evidence on
an ultimate issue of fact," citing Avirgan).
EFTA00729295
v. Epstein
Case No. 502008CA037319XXXXMIUD,
Epsteln's Response in Opposition to Motion for Leave