Epstein Secrets

w that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As

ted States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil

w that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As

ted States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil

08/2009 Page 2 of 25 C.M.A. v. Epstein, et al. Page 2 Defendant's motion). 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 (1994

sed minimum. As explained by the Landqraf court, supra at 280, and at 1505,2 2 In Landaraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before EFTA00201268 Case 9:08-cv-80811-KAM Document 78

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 (1994

of the amount of actual damages a plaintiff has suffered and proven. The new 3 In Landoraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined

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

uct 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 new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined

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 (199

uct 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 new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined

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

of the amount of actual damages a plaintiff has suffered and proven. The new 3 In Landoraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined

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

duct 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 new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. 'Ile Court determine

the statute books, and federal and state courts commonly read them to mandate ongoing equal treatment of two groups or objects. See, e.g., Adamson v. Bowen, 855 F. 2d 668, 671-672 (CA10 1988) (statute mak- ing United States liable for fees and expenses "to the same extent that any other party would be li

f the Civil Rights Act, the purpose here was not to ensure parity of treatment for interna- tional organizations and foreign governments. Instead, as the Court of Appeals for the D. C. Circuit pointed out years ago, the statute's reference to the immunities of 'foreign governments" was a "shorthand" for the immuni- tie