Epstein Secrets

nt be followed and fulfilled. Your truly, MARTIN WEINBERG, ESQ. ROY SACK, ESQ. /wg By Black. Srebnick. Kornspan & Stumpf. I'.A. EFTA00207723 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO

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

nt be followed and fulfilled. Your truly, MARTIN WEINBERG, ESQ. ROY LACK, ESQ. /wg By Black. Srebnick. Kornspan & Stumpf. I'.A. EFTA00213247 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO

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

ILEGED AND CONFIDENTIAL I2 ATTORNEY WORK PRODUCT Case No. 08-80736-CV-MARRA P-011801 EFTA00192847 Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

uct was completed before 2006. 1. Congress Dld Not Intend To Apply Masha's Law Retroactively. It is axiomatic that "retroactivity is not favored," Bowen'. Georgetown Univ. Hosp., 488 U.S. 204, 208 (1988), and the "traditional presumption teaches that [an amended statute) does not govern absent clear

296697325-L_801_0-1 6/10/2009 EFTA00175264 Case'9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 RIPON 1 105 0.1 ELECTRONIC UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Mar. 24, 2009 STEVEN m.LARim0RE CLERK N.S. DIST. CT. s.o. Or FLA.• MIAMI 09-80469-Civ-RYSKAMPNITUNAC JANE DOE II

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 (199

the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

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