Epstein Secrets

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

mproperly alleged multiple causes of actions under 18 U.S.C. §2255 in an attempt to multiply the presumptive minimum damages is the case of Gray v. Darby, slip copy, 2009 WL 805435 (E.D. Pa. Mar. 25, 2009). In that action, the plaintiff, a minor four year old boy, was enrolled at a church childcare f

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 v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199

se of action under §2255, a plaintiff is required to prove all the elements of one of the statutory enumerated criminal predicate acts. See Gray v. Darby, 2009 WL 805435 (ED. Pa. Mar. 25, 2005), requiring evidence to establish predicate act under 18 U.S.C. §2255 to state cause of action. I. A. The s

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

legations setting forth the requisite elements of the cited predicate act. See Smith v. Husband, 376 F.Supp.2d, and 428 Supp.2d, supra; and Gray v. Darby, 2009 WL 805435 (E.D. Pa. Mar. 25, 2005), requiring allegations/evidence to establish predicate act under 18 U.S.C. §2255 to state cause of action.