Epstein Secrets

ion of Law and Morals, 71 Harv. L. Rev. 593 (1958) 130 Sexual Abuse Prosecutions, 77 J. Crim. L. & Criminology 1 (1986) 24 xxvi EFTA00103025 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -x UNITED STATES OF AMERICA S 1 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x PRELIMINARY STATEMENT The G

new duties with respect to transactions already completed." Vernon v. Cassadaga Valley Cent. School Dist, 49 F.3d 886, 890 (2d Cir. 1995) (quoting Landgraf, 511 U.S. at 280). Applying Section 3283 here would have none of those effects. Maxwell's rights, liabilities, and duties were governed by the subst

Timely 23 A. Statutory Background 24 B. The 2003 Amendment to Section 3283 Applies Retroactively 26 1. The 2003 Amendment Satisfies Step One of Landgraf 28 2. The 2003 Amendment Satisfies Step Two of Landgraf 32 C. The Defendant's Crimes Involved the Sexual Abuse of Minors 36 III. The Defendant'

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

ng on or commenced after the date of enactment of this Act,' " "might possibly have qualified as a clear statement for retroactive effect" (quoting Landgraf, 511 U.S. at 260, 114 S.Ct. at 1494)); Rivers v. Roadway Express, Inc., 511 U.S. 298, 307-08, 114 S.Ct. 1510, 1517, 128 L.Ed.2d 274 (1994) (noting

ly retroactively. Congress may prescribe the temporal reach of a statute by stating that it applies to pre-enactment conduct, the first step in the Landgraf analysis, or a statute may be silent regarding temporal reach, in which case courts apply tho judicial presumption against retroactivity. This pres

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

n. 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 (1994): ... the presumption against retroactive legislation is deeply rooted in ou

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

n. 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 (1994): ... the presumption against retroactive legislation is deeply rooted in ou

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

entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landaraf the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply