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3 05 2010 Page 29 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra-Johnson Page 29 meaning of the statute would prevail. See United States v. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: ... The rule of lenity requires ambiguous
meaning of the statute would prevail. See United States v. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: ... The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them. See United
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199
and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t
eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199
and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t
eaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199
, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) t
meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf I. USI Film Products 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994
of inertia upon the party that can best induce Congress to speak more clearly and keeps courts from making criminal law in Congress's stead. ... In Santos. the Court was faced with the interpretation of the term "proceeds" in the federal money laundering statute, 18 . §1956. "The federal money-launder
aning of the statute would prevail. See United Statcs I. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed in B. 9 EF
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf I. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199
9-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 24 of 29 Jane Doe II v. Epstein, et al. Page 24 Plaintiff's view. See United States v. Santos, 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos supra, at 2025: ... The rule of lenity requires ambiguous
ein, et al. Page 7 (quoted above). See endnote 1 hereto, Complaint ¶11, 13.1 It is an axiom of law that "retroactivity is not favored in the law." Bowen 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landqraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994
, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos supra, at 2025: 3 See argument in sections (2) and (3) th
s, which is consistent with applicable law discussed more fully below herein. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf I. USI Film Products 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994
Entities connected to both Santos and Bowen

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Julie K. Brown
PERSONLeon Black
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON
John Kerry
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONMaria Farmer
PERSON
Merritt
PERSON
Vicky Ward
PERSON