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the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained: What Masha's law does, and what is incorporated in here, is it changes "any minor" t
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained: What Masha's law does, and what is incorporated in here, is it changes "any minor" t
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained: What Masha's law does, and what is incorporated in here, is it changes "any minor" t
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained: What Masha's law does, and what is incorporated in here, is it changes "any minor" t
Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 FL 33401-5012 Fax• 561-R15-R691 Counsel for Defendant Jeffrey Epstein Michael J. Pike, Esq. Florida Bar No. 617296 Burman Craton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Be Telephone: Facsimile: 15-3148
the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law-e xplained: What Masha's law does, and what is incorporated in here, is it changes "any minor" t
[email protected] Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 [email protected] Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
the unamended version of the law implicitly must have permitted victims to sue even after they turned 18. That interpretation not only would render Masha's Law superfluous; it would make Masha's Law's internally redundant, because Masha's Law retained the "legal disability" language from the 2003 vers
amendments were made by § 707 of the Adam Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are known as "Masha's Law." As Senator Kerry—the author of Masha's Law—explained: What Masha's law does, and what is incorporated in here, is it changes "any minor" to
bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. ntton, ., Esq. Florida Bar No. 2 162 [email protected] Michael J. Pike, Esq. Florida Bar No. 617296 [email protected] Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
mendments (cited above) where Congress unambiguously expressed its intent regarding retroactive application, there is no expression with respect to Masha's Law, the 2006 amended version of §2255. An EFTA00175271 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 9 of 11 Ja
anting the relief requested above, and for such other and further relief as this Court may deem just and proper. By: ROBERT D. C ITTON, JR., ESQ. MICHAEL J. PIKE, ESQ. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF.
e Suite 400 West Palm Beach , FL 33401-2918 Amiens United States of America represented by Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Michael James Pike Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: 51 -3148 Email: ATTORNEY TO BE NOTICED Un
of the history and purpose behind 18 U.S.C. §2255 and the assertion that "Congress specifically intended for the law to apply retroactively to her (Masha) even though she had already been abused and had already filed suit under §2255," (Response, p. 14), is not even supported by the Congressional Reco
Paul G. Cassell, Esq. Vic Co-counsel for Plaintiff Jane Doe Respectfully submitted, By: /s/ Robert D. Critton, Jr. ROBERT D. CRITION JR. ESQ. MICHAEL J. PIKE, ESQ. BURMAN, CRITFON, LUTTIER & COLEMAN (Co-Counsel for Defendant Jeffrey Epstein) EFTA00611611
of the history and purpose behind 18 U.S.C. §2255 and the assertion that "Congress specifically intended for the law to apply retroactively to her (Masha) even though she had already been abused and had already filed suit under §2255," (Response, p. 14), is not even supported by the Congressional Reco
Hac Vice Co-counsel for PlaintiffJane Doe EFTA00611598 Jane Doe v. Epstein Case No. 08-CV-80893-Mans-Johnson Page 10 Respectfully submitted, MICHAEL J. PIKE, ESQ. la BURMAN, CRITTON, LUTHER & COLEMAN (Co-Counsel for De endant Je ey Epstein) EFTA00611599
ein, et al. Page 6 not a procedural one. As discussed more fully in Defendant's motion to dismiss, the statutory scheme enacted and amended under "Masha's Law" is consitently referred to as criminal penalties and punishments directed at those who sexually exploit and abuse minors. Also, Plaintiff i
ndant requests that this Court grant his motion to dismiss and strike. By: ROBERT . CRITTON, JR., ESQ. Florida B r No. 224162 L.Mi:Icicla)&gpLn MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of th
Entities connected to both Masha Drokova and Michael J. Pike

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSONKatherine W. Ezell
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSONIsidro Manuel Garcia
PERSON
Lesley Groff
PERSON
Kenneth Marra
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONSouthern District
LOCATIONScott Rothstein
PERSONBruce E. Reinhart
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSON
Sarah Kellen
PERSONMaria Farmer
PERSON