9
Shared Docs
9
Same-Page
9 / 9
Mentions
IM G., the first victim identified in PBPD's investigation. Plaintiff filed motion to remand to state court, which was granted by Judge Marra. 2. Jane Doe #2I. Epstein, 08-CV-80 I 19-KAM: Complaint filed on February 6, 2008, alleging: sexual assault (Count l), and intentional infliction of emotional di
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
a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to (6) In or around 2002, Defendant JEFFREY EPSTEIN paid $400 to Jane Doe #2, who was then fifteen years' old, to (7) In or around 2002, Defendant JEFFREY EPSTEIN asked.Jane Doe #2 if she had any younger friends who woul
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
case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00077698 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
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
case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00039513 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
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
8's eighteenth birthday, and when Jane Doe #19 was seventeen years old. [NB: The police report describes a pattern of activity, including dates when Jane Doe #18 was seventeen years old.] Neither Jane Doe #18 nor #19 ever returned to Epstein's home. Although we have not yet obtained Jane Doe #18's teleph
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
012635 TAB 32 HOUSE_OVERSIGHT_012636 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 20069 " JANE DOE NO. 1, by and through JANE DOE’s FATHER as parent and natural guardian, and JANE DOR’s FATHER, and . . JANE DOE’s STEPMOTHER, individually, ciV-MA RRA Plaintiffs, MAGISTRATE JUDGH
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
to Compel Response to 1st RTP and 1st Interrogs filed by . (Hill, Jack) (Entered: 04/20/2009) 04 /22%2009 63 r 313:: MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to File Brief as Amicus Curiae in Support of Plaintiffs Response in Opposition to Defendant Jeffrey Epstein's Motion to
ports, cited above herein, consistently referring to the presumptive minimum damages amount under §2255 as "punishment" or "penalties? According to the Ex Post Facto doctrine, although §2255 is labeled a "civil remedy," such label is not dispositive; "if the effect of the statute is to impose punishment that is
case. AUSA- I also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 EFTA00103091 requested the same relating to Jane Doe 43 v. Epstein, et al., 17 Civ. 0616 (JGK) (SN). Because of the ongoing and covert nature of the grand jury investigation, and consistent with its st
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
etisatabnFIESB0DEitdaidagaMGM 6 P r. fc2 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. GOVERNMENT'S NOTICE OF FILING DECLARATION OF FBI SPECIAL AGENT TIMOTHY R. Responden
Case 9:08-cv-80736-KAM Document 361-39 Entered on FLSD Docket 02/10/2016 Page 4 of 6 so novel as to implicate the so-called "dear statement rule," the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. =may elect to proceed with the case. Absence of coercion. With respect to 1
Entities connected to both Jane Doe and the Ex Post Facto

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONKatherine W. Ezell
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON