Epstein Secrets

ach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

nce at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

w that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As

of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COM

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAIN

08/2009 Page 2 of 25 C.M.A. v. Epstein, et al. Page 2 Defendant's motion). It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landqraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994

13 Entered on FLSD Docket 05/06/2009 Page 2 of 29 Jane Doe II v. Epstein. et al. Page 2 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and Sarah Kellen, (hereinafter "state action"). In attempting to allege a claim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effect

ENDNOTES: 1 In paragraph 11 of her Complaint, Jane Doe II alleges that — "From about June, 2003 until about February, 2005, Defendants, EPSTEIN and KELLEN persuaded, induced, or EFTA00222839 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 28 of 29 Jane Doe II v. Epstein,

ein, et al. Page 7 (quoted above). See endnote 1 hereto, Complaint ¶11, 13.1 It is an axiom of law that "retroactivity is not favored in the law." Bowen 488 U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landqraf v. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994

y is identical. 8. C.M.A. I. Epstein, 08-CV-80811-KAM: This suit was filed in state court and removed to federal court. Plaintiff sued Epstein and Sarah Kellen (Epstein's assistant). Kellen is represented by Bruce Reinhart. CMA's initial Complaint alleged sexual abuse and intentional infliction of emotiona

n, 08-CV-80811-KAM: This suit was filed in state court and removed to federal court. Plaintiff sued Epstein and Sarah Kellen (Epstein's assistant). Kellen is represented by Bruce Reinhart. CMA's initial Complaint alleged sexual abuse and intentional infliction of emotional distress. CMA later filed a

uct was completed before 2006. 1. Congress Dld Not Intend To Apply Masha's Law Retroactively. It is axiomatic that "retroactivity is not favored," Bowen'. Georgetown Univ. Hosp., 488 U.S. 204, 208 (1988), and the "traditional presumption teaches that [an amended statute) does not govern absent clear

ss - Shared Government Illegal Surveillance Refer to attached - Hand written note I enquired at the Interflora Florists, owner Kandice - Flowers on Ellen, Floral Trends, Port Pirie Kandice stated that she could not find the file on their computer base file or payment details of the sender and that s

02.04.2053 MN: Phone: 08 8632 1244 Fax: 08 8633 0579 blightsewestnetcom.au www.professionals.com.au TAX INVOICE ReinT pelkr) -to (271 it 'goa) Bowen FOR 11 MEAOOv4 CRESeaT Re LOC -A-TE (a3 i 't lac`a) To: David Johnson & Property Owners: Tracey Heimers Re Property at Inv No Due Date Account