Epstein Secrets

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

3 F.3d 1256 (11th Cir. 1998). U.S. v. Edwards, 162 F.3d 87 (3d Cir. 1998); and generally Calder v. Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798). The United States Constitution provides that Injo Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art. I,

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,

t 05/06/2009 Page 9 of 29 Jane Doe II v. Epstein, et al. Page 9 1998); and generally, Calder v. Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798). The United States Constitution provides that "[n]o Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art. I

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

l of otherwise barred claims fell squarely within a category of ex post facto laws condemned by the Supreme Court's seminal ex post facto decision, Calder'. Bull—namely, laws providing for "punishments, where the party was not, by law, liable to any punishment." Id. at 612 (quoting Calder, 3 Dail. 386,

of excitement and anticipation. INT. DINING ROOM - CONTINUOUS A party in progress, dinner already served. Seated around a large square table are: ELLEN (60, Robert's wife), BROOKE (36, Robert's daughter), PETER (34, Robert's son), TOM (Brooke's husband), ANNE (Peter's wife), and THREE GRANDCHILDRE

l get you a tour... (MORE) EFTA00724971 57. ELLEN (CONT'D) Yes, we're there once a week, all my kids did summers there, it would be great for Sarah, you really get involved, you know, it's not just writing a check... Mae enters. MAE (softly) There's a Detective Gower on the line. Ellen hol

t an employee. ROBERT Not an employee. I was an investor. GOWER What made you invest? ROBERT She had a great eye. She found me (points) those Calder prints, the ones on the wall there. They appreciated quickly, and on the strength of that I agreed to fund some of the gallery. GOWER (after a b

of excitement and anticipation. INT. DINING ROOM - CONTINUOUS A party in progress, dinner already served. Seated around a large square table are: ELLEN (60, Robert's wife), BROOKE (36, Robert's daughter), PETER (34, Robert's son), TOM (Brooke's husband), ANNE (Peter's wife), and THREE GRANDCHILDRE

. (MORE) EFTA_R1_02008857 EFTA02685420 57. ELLEN (CONT'D) Yes, we're there once a week, all my kids did summers there, it would be great for Sarah, you really get involved, you know, it's not just writing a check... Mae enters. MAE (softly) There's a Detective Gower on the line. Ellen hol

t an employee. ROBERT Not an employee. I was an investor. GOWER What made you invest? ROBERT She had a great eye. She found me (points) those Calder prints, the ones on the wall there. They appreciated quickly, and on the strength of that I agreed to fund some of the gallery. GOWER (after a b