Epstein Secrets

ified in the federal investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest thc jurisdiction of the U.S. District Court for the Southern District of Florida over his person and the subject matter. Epstein will not contest that identified victims are persons who, while minors, were victims of

Document 29 Entered on FLSD Docket 05/26/2009 Page 8 of 36 B. Masha's Law Does Not Apply To This Case. The presumption against retroactivity and the Ex Post Facto clause preclude application of Masha's Law in this case, where the alleged predicate conduct was completed before 2006. 1. Congress Dld Not Intend

mi Field Office ort t iami eac t, 9 Re: Freedoth of Information Act/Privacy Act Request ..Seeking:Documents from a USA° / FBI Investigation in the Southern District of Florida. ! • To Whom it Miy Concern: We write on behalf of our client,ltfaSt, to request certain records under the Freedom of Information Ac

ot be 2 EFTA01718491 05/16/2008 11:16 FAX 05/18/08 FRI 11:09 FAX @004/006 1004 so novel as to implicate the so-called "clear statement rule," the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. Absence of coercion. With respect

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

of limitations for such crimes through the lifetime of the victim. 30 EFTA00099997 the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that concern is entirely separate from extending the statute of limitations for live claims, which is what Congress did here. Critica

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

Leahy's comments indicate that Congress declined to add language that would allow for the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that conduct in 2000). Indeed, that is precisely what Congress authorized when it extended the statute of limitations for such crimes

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

Leahy's comments indicate that Congress declined to add language that would allow for the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that conduct in 2000). Indeed, that is precisely what Congress authorized when it extended the statute of limitations for such crimes

gned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARGES IN THE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate co

ct future behavior *1039 and that the question is so vague as to be meaning- less. That calls into play the concept our Court of Appeals applied to the Ex Post Facto r Clause (albeit in a different con t from the present one) in United States Sutton, 521 F.2d 1385, 1390- (7th ir.1975) (quoting United State

upplied in order to provide helpful background information about the Grand Jury. The Grand Jury consists of from sixteen to twenty-three persons from the Southern District of - Florida. It-is their responsibility to inquire into federal crimes which may have been committed m this District. Asa Grand Jury witness you

HOUSE_OVERSIGHT_012671 2] 004/006 05/16/2008 11:16 FAX ioe 05/16/08 FRI 11:09 FAX 80 novel as to implicate the so-called “‘clear statement rule,” the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. Absence of coercion. With respect

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

of limitations for such crimes through the lifetime of the victim. 30 EFTA00103055 the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that concern is entirely separate from extending the statute of limitations for live claims, which is what Congress did here. Critica