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so would violate the Ex Post Facto Clause of the United States Constitution. See U.S. Const. art I, §9, el. 3." The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to this action. In resolving the issue in favor of the defendant, the Court first considered whether a restitution order is
ages in order to property preserve all issues pertaining to the proper 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 20
tions to the victims — and having induced reliance by the victims — the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
egations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 43 of 54 Petitioners' allegations pro
Jersey. I am also admitted to the practice in the United States District Court for the Southern District of Florida, the U.S. Court of Appeals for the Eleventh Circuit, the U.S. Supreme Court, and several other federal courts. 3. I graduated from Princeton University in 1984 with a B.S.E. in civil engineering cu
egations in depositions and other court filings. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 08-80736-CV-MARRA 000861 EFTA00230685 fmney,'" Case 9:08-cv-80736-KAM Document 62 Entered on FLSD Docket 04/08/2011 Page 4
Entities connected to both the Eleventh Circuit and Marra/Johnson

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONLeon Black
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Supreme Court
ORGANIZATION
Alan Dershowitz
PERSON
United States District Court
ORGANIZATIONRoy Black
PERSON