Epstein Secrets

to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d

NITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/2010) Defendant

to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. I, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d

testimony, she was brought by another minor girl (Jane Doe No. 3) to EPSTEIN's Palm Beach home the one time

tion sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. I, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FN19. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9, cl

ersion of 18 U.S.C. §2255, effective 1999 to Jul. 26, 2006, the period of time during which EPSTEIN's alleged conduct occurred, applies to Plaintiff JANE DOE's claim brought pursuant to §2255 in Count II of the First Amended Complaint [D.E. 38]; (2) the version of 18 U.S.C. § 2255 in effect when the predic

tion sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FN19. Article I contains two Er Post Facto Clauses, one directed to Congress (§ 9, cl

, FL 33401-6223 Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to Dismiss, and thereafter an Answer, to claims brought by Jane Doe 103 pursuant to 18 USC §2255 that were referenced in our earlier letter to you dated March 5, 2010, to which there has been no response. We firmly

tion sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FN19. Article I contains two Er Post Facto Clauses, one directed to Congress (§ 9, cl

, FL 33401-6223 Jeffrey Epstein has an April 5, 2010 deadline for the filing of a Motion to Dismiss, and thereafter an Answer, to claims brought by Jane Doe 103 pursuant to 18 USC §2255 that were referenced in our earlier letter to you dated March 5, 2010, to which there has been no response. We firmly

ation sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Usetyl. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). F1419. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9, c

se to our requests during our meeting of February 3. Since February 11, 2010, a lawsuit has been filed by the attorney representative on behalf of Jane Doe 103. Her identity is known by us and she is on the "identified list." Her lawsuit raises only §2255 claims. Although she has not waived her right

ation sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Useryl. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FN19. Article 1 contains two Ex Post Facto Clauses, one directed to Congress (§ 9, cl

you have asked us to provide such an advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006 through 2007 investigation that culminated in the signing of the Non-Prose

tion sufficient to validate a statute's prospective application under the Clause "may not suffice" to warrant its retroactive application. Usery v. Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FN19. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9, cl

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style

cation sufficient to validate a statute's prospective applicagion under the Clause "may not suffice" to warrant its retroactive application. Usery Turner Elkhorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893, 49 L.Ed.2d 752 (1976). FNI9. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9, cl

r Ft. Lauderdale. FL 33394 Re: B.B. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Ms. Villafana: As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation against Jeffrey Epstein styled B.B. I Jeffrey Epstein. case no.: 502008CA037319 MB AB. We are hereby requestin