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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
d) disadvantage[s] the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Siegel
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
] disadvantage[s) the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lvnce v. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham, 450 U.S. 24, 29,101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Siegel
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
] disadvantage[s] the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Siege
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
disadvantage[s] the offender affected by it' by altering the definition of criminal conduct or increasing the punishment for the crime." 14/rice v. Mathis 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Sieuel,
Entities connected to both Bowen and Mathis

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATIONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
John Kerry
PERSON
Prince Andrew
PERSONJane Doe
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Scarlett Johansson
PERSONCalder
ORGANIZATIONLeon Black
PERSONMichael J. Pike
PERSON
Merritt
PERSON
Legislature
ORGANIZATION
United States District Court
ORGANIZATIONWeaver
PERSONCalder v. Bull
PERSON