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where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l
jagesq®bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 mpike®bc1claw.com Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l
Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 FL 33401-5012 Fax• 561-R15-R691 Counsel for Defendant Jeffrey Epstein Michael J. Pike, Esq. Florida Bar No. 617296 Burman Craton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Be Telephone: Facsimile: 15-3148
where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
ention of the Er Post Facto clause. The Supreme Court's decision in California v. Stogner, 539 U.S. 607 (2003), perfectly illustrates the point. In Stogner, the defendant was charged in 1998 based on sex crimes that he allegedly committed between 1955 and 1973. While the original three-year statute of l
[email protected] Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. Critton, Florida Bar No. 2 162 rcrit@bc1claw. Michael J. Pike, Esq. Florida Bar No. 617296 [email protected] Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
where the party was not, by law, liable to any punishment." After (but not before) the original statute of limitations had expired, a party such as Stogner was not "liable to any punishment." California's new statute therefore "aggravated" Stogner's alleged crime, or made it "greater than it was, when
Post Facto clause precludes the revival of claims predicated on past crimes. The precise concerns animating Stogner are present in this case. As in Stogner Defendant was "liable to punishment" under § 2255 before Plaintiff turned 18, but once she attained that age, he no was longer "liable to punishmen
bellsouth.net Counsel for Defendant Jeffrey Epstein Respectfully submitted: By: Robert D. ntton, ., Esq. Florida Bar No. 2 162 [email protected] Michael J. Pike, Esq. Florida Bar No. 617296 [email protected] Burman Critton Luther & Coleman, P.A. 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401
Entities connected to both Stogner and Michael J. Pike

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSONKatherine W. Ezell
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Scarlett Johansson
PERSON
George W. Bush
PERSON
Sarah Kellen
PERSONMaria Farmer
PERSON
United States District Court
ORGANIZATION
Podhurst Orseck
ORGANIZATION
United States
LOCATIONMartin Weinberg
PERSONthe Southern District
LOCATIONLeon Black
PERSON
A. Marie Villafana
PERSON