3
Shared Docs
3
Same-Page
3 / 3
Mentions
original memorandum, that Defendant EPSTEIN may not contest this Court's jurisdiction based on the Non Prosecution Agreement ("NPA"). Although the State Court action is not a part of this Complaint, and is not alleged in the four (4) corners of it, it is a fact that cannot be contested since Plaintiff has
s were possessed; the Court held the legislative amendment was a mere clarification of the prior legislation and not an ex post facto law. Justice Scalia cited the statement of purpose of the Civil Rights Act of 1991, to hold that, for example, the amendments specifically designed to overrule Patterso
), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c
es were possessed; the Court held the legislative amendment was a mere clarification of the prior legislation and not an ex post facto law. Justice Scalia cited the statement of purpose of the Civil Rights Act of 1991, to hold that, for example, the amendments specifically designed to overrule Patterso
), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c
were possessed; the Court held the legislative amendment was a mere clarification of the prior legislation and not an ex post facto law. 9 Justice Scalia cited the statement of purpose of the Civil Rights Act of 1991, to hold that, for example, the amendments specifically designed to overrule Patterso
Entities connected to both State Court and Scalia

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
United States
LOCATION
George W. Bush
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONLeon Black
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON
A. Marie Villafana
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Ken Starr
PERSONMaria Farmer
PERSON
Jay Lefkowitz
PERSON