Epstein Secrets

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at two district 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 a

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at two district 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 a

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at two district 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 a

d this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 26th day of May , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orsecic, P.A. 25 West Flagler Street, Suite 800 Fax• 105 15R-910 Counsellor Plaintiff Jack Alan Goldber

at two district 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 a

ed this day on all counsel of record identified on the following Service List in the manner specified by CWECF on this 26th day of Mav , 2009 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 rjosefsb

at two district 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 a

ography); and § 2252A(g) (engaging in a child exploitation enterprise). 12. Doe No. 102 I. Epstein, 09-CV-80656-KAM: This suit also was filed by Josefsberg's firm. On May I, 2009, Plaintiff filed suit alleging the same claims raised by Doe No. 101. Epstein has not yet filed his answer to that Complaint.

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