Epstein Secrets

ase LLP (DC), David Charles Frederick, John Christopher Rozendaal, Mark Charles Hansen, Michael John Guz- man, Michael K. Kellogg, Kellogg, Huber, Hansen, Todd & Evans PLLC (DC), Law- rence Saul Robbins, Robbins Russell Eng- lert Orseck & Untereiner LLP, Washing- ton, DC, Jean Engelmayer Kalicki, Arnol

i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where

m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212905 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212972 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221375 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221472 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

uent travel, and that any sexual activity—legal or not—that occurred was incidental to the legitimate purposes that motivated his trips. See, e.g., Hansen, 291 U.S. at 562-63 ("[TJo say that, because [persons) indulge in illegal or immoral acts, they travel for that purpose, is to emphasize that which

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00189761 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

Page 28 of 36 the same act are intended to have the same meaning.") (quotation and citation omitted). Two Mann Act cases are particularly apt. In Hansen', Half, 291 U.S. 559 (1934), the Government charged the defendant with violating the Mann Act after she returned to the country with a man with who

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto decision, Calder'. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dail. 386,