Epstein Secrets

City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Robert Deweese Critton , Jr. Burman Critton Luttier & Coleman https://ecf.flsd.useourts.gov/egi-bin/DIctRpt.p17825839498761356-L_801_0-1 6/10/2009 EFTA00175220 CM/ECF

/04/2009) 05/11/2009 5 r RESPONSE/REPLY to 4 Sealed Document, 3 Sealed Document Opposition to Motion to Proceed Anonymously by Jeffrey Epstein. (Critton, Robert) (Entered: 05/11/2009) 05/11/2009 6 r NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf of Jeffrey Epstein (Critton

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

iew Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement"), s

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

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 Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply

iew Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement"), s

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

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

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

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

, Defendant requests that this Court dismiss the entire action against him, and further grant his motion for more definite statement and to strike. Robert D. Critton, Esq. Attorney for Defendant Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

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

SES ONLY) 20* NOTE: IN LAND CONDEMNATION OASES. fay. 24, THE 7 LAND 'IWO/val. SYEVEm R4 LARluODE AC I Attorneys Or Keen) CLERK U.S. DIST. CT. Robert D. Critton, Esq., Burman, (..sitioltaataCaitIL.L...p, • 303 Banyan Blvd., Suite 400, West Palm Beach, FL 33401 WI Check County Whine Mien &OM CI MIAMI. OAHE

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