Epstein Secrets

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

ion." EFTA00222830 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appro

ecoverable on a "per violation" or "per incident" basis. The Plaintiff's position on §2255 puts a strained interpretation with an absurd result. In Martinez v. White, supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of Califor

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

suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 P.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat

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

who suffers personal injury as a result of such violation." "18 . §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 §2255 "merely provides a cause of action for damages in `any appropriate United States Distr

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

er of EFTA00175292 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appr