Epstein Secrets

application of §2255 for appeal. See C.MA. v. Epstein, Case No. 08-CIV-80811 Marra/Johnson; and Jane Doe II v. Epstein, Case No. 09-CW-80489 Marra/Johnson. EFTA00207698 Case 9:08-cv-80893-KAM Document 128 Entered on FLSD Docket 03 05 2010 Page 23 of 36 Jane Doe v. Epstein Case No. 08-CV-80893-Marra

irected to Congress (§ 9, cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as applicable only to penal legislation. See Calder v. Bull, 3 Dail. 386, 390-391, 1 LEd. 648 (1798) (opinion of Chase, J.). These provisions demonstrate that retroactive statutes raise particular concerns.

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto 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 (1

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto 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 (1

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto 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 (1

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto 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 (1

ment 13 Entered on FLSD Docket 05/06/2009 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT, AND SUPPORTING MEMORANDUM

irected to Congress (§ 9, cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as applicable only to penal legislation. See Calder v. Bull, 3 Dail. 386, 390-391, 1 L.Ed. 648 (1798) (opinion of Chase, J.). EFTA00222819 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto 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 (1

ocument 19 Entered on FLSD Docket 02/27/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08- 80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AMENDED COMPLAINT Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Com

irected to Congress (§ 9, cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as applicable only to penal legislation. See Calder v. Bull, 3 Dail. 386, 390-391, 1 L.Ed. 648 (1798) (opinion of Chase, J.). EFTA00175287 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/