Epstein Secrets

ant Jeffrey Epstein Date Filed: 05/01/2009 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Federal Question represented by Katherine Warthen Ezell Podhurst Orseck Josefsberg et al City National Bank Building 25 W Flagler Street Suite 800 Miami FL 33130-1780 Fax: Email: LEAD ATTORNEY ATT

filed by Jane Doe No. 101.(Ezell, Katherine) (Entered: 05/01/2009) 05/01/2009 8 r 173 KB RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe No. 101. (Ezell, Katherine) (Entered: 05/01/2009) 05/01/2009 9 ri 61.2 KB First AMENDED COMPLAINT and Demand For Jury Trial, filed by Jane Doe No. 101.(Ezell

e 6 of 7 Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al. (Ezell, Katherine) (Entered: 06/04/2009) 06/04/2009 28 ORDER STRIKING (112 in 9:08-cv-80381-ICAM, 111 in 9:08-cv-80232- KAM, 136 in 9:08-cv-80119-KAM, 11

ng on or commenced after the date of enactment of this Act,' " "might possibly have qualified as a clear statement for retroactive effect" (quoting Landgraf, 511 U.S. at 260, 114 S.Ct. at 1494)); Rivers v. Roadway Express, Inc., 511 U.S. 298, 307-08, 114 S.Ct. 1510, 1517, 128 L.Ed.2d 274 (1994) (noting

ly retroactively. Congress may prescribe the temporal reach of a statute by stating that it applies to pre-enactment conduct, the first step in the Landgraf analysis, or a statute may be silent regarding temporal reach, in which case courts apply tho judicial presumption against retroactivity. This pres

l counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldbe

n. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994): ... the presumption against retroactive legislation is deeply rooted in ou

l counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2010. 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 [email protected] kezell@p

n. It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994): ... the presumption against retroactive legislation is deeply rooted in ou

of right by a jury. Date: C44.ArtatA4-1.2)-3 , 2010. Respectfully Submitted, By: iRreat fia—Plef'-b W4P/ Robert C. Jose erg Bar No. 040856 Katherine W. Ezell Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler St., Suite 800 Miami, Florida 33130 Telephone: (305) 358-2800 Fax: (305) 358-2382 rjosefs

entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply

triable as of right by a jury. Date: 4artitA4-1-i-3 , 2010. Respectfully Submitted, By: ke-PO4 fe-Peet-vbv Robert (.Jose erg Bar No. 040856 Katherine W. Ezell Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler St., Suite 800 Miami, Florida 33130 Telephone: (305) 358-2800 Fax: (305) 358-2382 sefsber

entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landaraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply

ll issues triable as of right by a jury. Date: ‘44..Art.AA-r-12)-3 , 2010. Respectfully Submitted, By: R-W- C. e-pecli lay Robert r Jose e g Katherine W. Ezell Attorneys or Plaintiff Podhurst Orseck, P.A. 17 25 West Hagler Street, Suite 800„ Miami, FL 33130, Miami 31:6393.2800 Fax 305.358.2382 • Fort Lau

entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landaraf the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply