Epstein Secrets

ra-Johnson Page 29 Respectfully submitted, By: Isl Robert D. Critton, Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar N

ncy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability

a matter of law to the summary judgments sought. WHEREFORE, Defendant requests that this Court enter the summary judgments sought herein. By: re Robert D. Critton. Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PUCE, ESQ. Florida Bar #617296 mnikalclaw.com I HEREBY C

Entered on FLSD Docket 03/05:2010 Page 21 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra-Johnson Page 21 double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity

alm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515

sewhere did expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity

alm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515

sewhere did expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity

alm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515

sewhere did expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity

alm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 [email protected] Burman Critton Luther & Coleman, P.A. 515

sewhere did expressly. In these circumstances, the traditional rules against surplusage and redundancy apply with double force. See, e.g., Duncan v. Walker, 533 U.S. 167, 174 (2001). The "legal disability" language in § 2255(b) should be interpreted to reference classic legal disabilities like insanity

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

ment that called for court to unlawfully sentence the defendant by treating two misdemeanor offenses as felony offenses); see also United States v. Walker, 98 F.3d 944, 946-47 (7th Cir. 1996) (concluding that judge was not compelled to impose a concurrent sentence where judge had erroneously represent

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

ment that called for court to unlawfully sentence the defendant by treating two misdemeanor offenses as felony offenses); see also United States v. Walker, 98 F.3d 944, 946-47 (7th Cir. 1996) (concluding that judge was not compelled to impose a concurrent sentence where judge had erroneously represent

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

ment that called for court to unlawfully sentence the defendant by treating two misdemeanor offenses as felony offenses); see also United States v. Walker, 98 F.3d 944, 946-47 (7th Cir. 1996) (concluding that judge was not compelled to impose a concurrent sentence where judge had erroneously represent

right by a jury. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by facsimile and United States mail to: Robert D. Critton, Esquire and Michael J. Pike, Esquire, Burman, Critton, et al., Attorneys for Defendant, 515 North Flagler Drive, Suite 400, West Palm Beach, Flori

ment that called for court to unlawfully sentence the defendant by treating two misdemeanor offenses as felony offenses); see also United States v. Walker, 98 F.3d 944, 946-47 (7th Cir. 1996) (concluding that judge was not compelled to impose a concurrent sentence where judge had erroneously represent