Epstein Secrets

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212905 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00212972 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221375 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00221472 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and

o decision, Calder v. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dall. 386, 391 (1798)). -13- EFTA00189761 Case 9:09-cv-80591-KAM Document 29 Entered on FLSD Docket 05/26/2009 Page 14 of 36 The second cat

courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth above and