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ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l

ted with an expectation that the principle will apply except 'when a statutory purpose to the contrary is evident.'" Id. (quoting Isbrandtsen Co. v. Johnson 343 U.S. 779, 783 (1952)). In this case, however, the Court need not take anything "as given." Even if the statute's language were not clear—which

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l

R THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Plaintiff, VS. JEFFREY EPSTEIN, 09 - 8059 1 Civil Action No. CIV-MARRP MAGISTRATE JUDGE JOHNSON Etrpy ,fir DC INTAKE APR 1 7 2009 STEVEN M. LARIMORE CLERK U.S. OIST. CT. S.O. OF FLA. MIAMI COMPLAINT AND Defendant. DEMAND FOR JURY TRIA

where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when

Post Facto clause precludes the revival of claims predicated on past crimes. The precise concerns animating Stogner are present in this case. As in Stogner Defendant was "liable to punishment" under § 2255 before Plaintiff turned 18, but once she attained that age, he no was longer "liable to punishmen

62 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Joseph berg, 459 F.3d 350 (2d

1) 109, 113 viii EFTA00099949 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith y. Maryland, 442 U.S. 735 (1979) 117, 118 Stogner v. California, 539 U.S. 607 (2003) 45 Swain v. Alabama, 380 U.S. 202 (1965) 300 Taylor v. Louisiana, 419 U.S. 522 (1975) 299,300 Taylor v. U

2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994)

01) 109, 113 viii EFTA00077614 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith v. Maryland, 442 U.S. 735 (1979) 117, 118 Stogner v. California, 539 U.S. 607 (2003) 45 Swain v. Alabama, 380 U.S. 202 (1965) 300 Taylor v. Louisiana, 419 U.S. 522 (1975) 299, 300 Taylor v.

2014) 140 Int'l Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994)

01) 109, 113 viii EFTA00039429 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith v. Maryland, 442 U.S. 735 (1979) 117, 118 Stogner v. California, 539 U.S. 607 (2003) 45 Swain v. Alabama, 380 U.S. 202 (1965) 300 Taylor v. Louisiana, 419 U.S. 522 (1975) 299, 300 Taylor v.

014) 140 Intl Equity !nvs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 111 Johnson v. United States, 520 U.S. 461 (1997) 200 Kungys v. United States, 485 U.S. 759 (1988) 222 Landgraf v. USI Film Products, 511 U.S. 244 (1994)

1) 109, 113 viii EFTA00103007 Silver, 15 Cr. 93 (VEC) 275 Skelos, 15 Cr. 317 (KMW) 275 Smith v. Maryland, 442 U.S. 735 (1979) 117, 118 Stogner v. California, 539 U.S. 607 (2003) 45 Swain v. Alabama, 380 U.S. 202 (1965) 300 Taylor v. Louisiana, 419 U.S. 522 (1975) 299, 300 Taylor v.