See Baxter v. Palmigiano, 425 U.S. 308, 318 (1976)(holding that
respondent's Fifth Amendment rights were not violated where he was advised that he was not required to testify but that his
silence could be held
against him); Lefkowitz v. Cunningham, 431 U.S. 801, 808 n. 5 (1977)(clarifying that Baxter permitted an adverse inference to be drawn in a civil case from a party's refusal to testify, but that the Baxter
respondent's
silence «was only one of a number of factors to be considered»).