3
Shared Docs
3
Same-Page
3 / 3
Mentions
om passing another type of retroactive legislation, laws "impairing the Obligation of Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of "just compensa
ally identified in subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed to sufficiently allege the predicate act(s) required by §2255. Defendant has no objection to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause of action
rom passing another type of retroactive legislation, laws "impairing the Obligation of Contracts! The Fifth Amendment's Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of lust compensat
tify that Plaintiff was paid by others for similar sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in certain act(s) that would negate or lessen her damages. This goes directly to Plaintiff's damage claim. 7. Likewise, subpoenas must be issued to third-party tre
FLSD Docket 05/08/2009 Page 3 of 25 v. Epstein, et al. 113 These provisions demonstrate that retroactive statutes raise particular concerns. The Legislature's unmatched powers allow it to sweep away settled expectations suddenly and without individualized consideration. Its responsivity to political pre
ally identified in subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed to sufficiently allege the predicate act(s) required by §2255. Defendant has no objection to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause of action
Entities connected to both Legislature and act(s

Jeffrey Epstein
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
New York
LOCATIONLeon Black
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Barry Diller
PERSON
Julie K. Brown
PERSON
Palm Beach County
LOCATION
U.S. Virgin Islands
LOCATION
Joe Biden
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSONRobert D. Critton
PERSON