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rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
the "predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White, 492 EFTA00201194 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 6 of 21 C.M.A. v. Epstein, et al. Page 6
rther evidenced by Count XXXI — "Sexual Battery" where Plaintiff reincorporates each of the 30 counts and seeks the identical "actual damages." In Martinez v. White, supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of Califor
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
ion." EFTA00222830 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appro
ecoverable on a "per violation" or "per incident" basis. The Plaintiff's position on §2255 puts a strained interpretation with an absurd result. In Martinez v. White, supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of Califor
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails t
suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White, 492 F.Supp.2d 1186, 1188 (ND. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Sta
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat
principle of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States'. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
suffers personal injury as a result of such violation." "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez'. White, 492 P.Supp.2d 1186, 1188 (N.D. Cal. 2007). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in `any appropriate United Stat
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
er of EFTA00175292 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White, 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appr
rinciple of fair warning - ... a criminal statute must give fair warning of the conduct that it makes a crime ... . As was said in United States v. Harriss, 347 U.S. 612, 617, 74 S.Ct. 808, 812, 98 L.Ed. 989, 'The constitutional requirement of definiteness is violated by a criminal statute that fails
the "predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 EFTA00175344 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 7 of 21 v. Epstein, et al. age v. Husban
Entities connected to both Harriss and Martinez

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
George W. Bush
PERSON
Colorado
LOCATION
Bradley Edwards
PERSONFBI
ORGANIZATION
Michael Cohen
PERSON
Supreme Court
ORGANIZATIONMartin Weinberg
PERSON
James Baker
PERSONJane Doe
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
Eric Schmidt
PERSON
United States District Court
ORGANIZATION