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

he legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and universal appeal." Kaiser, 494 U.S., at 855, 110 S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in both commercial and artistic endeavors is

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,

he legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and universal appeal." Kaiser, 494 U.S., at 855. 110 S.Ct., at 1586 (SCALIA, J., concurring). In a free, dynamic society, creativity in both commercial and artistic endeavors is

From: Sarah K To: "Kaiser, Pamela" Subject: Re: Paris Date: Tue, 27 Sep 2011 15:14:03 +0000 Yes, I phoned him at the Four Seasons. He should already be at Jeff

t the Four Seasons. He should already be at Jeffreys apt now. Thanks for your help.. On Sep 27, 2011, at 11:11 AM, "Kaiser, Pamela" alMin wrote: > Sarah, > Have you and Reid been in contact? Thanks. > Pam > Pamela C. Kaiser > Legal Executive Assistant to Reid H. Weingarten > Steptoe & Johnson LLP

From: Sarah K To: "Kaiser, Pamela" Subject: Re: Paris Date: Tue, 27 Sep 2011 15:14:03 +0000 Yes, I phoned him at the Four Seasons. He should already be at Jeffreys apt now.

,REBECCA VAN DER GRIFT,PAUL J ASCHE,SARAH P KAHLE,KENT HOUSE,NADINE BRIG

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