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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
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
d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
of limitations for such crimes through the lifetime of the victim. 30 EFTA00099997 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
d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
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
d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
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
ot yet obtained Jane Doe #18's telephone records, we were able to identify her telephone number, and there are twenty telephone calls that appear on Sarah Kellen's phone records. All of those calls were outgoing (meaning Kellen called Jane Doe #18.) The telephone calls range in date from August 27, 2003 throu
each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually Kellen—in the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage
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
13. Epstein’s plan and scheme reflected a particular pattern and method. Upon arrival at Epstein’s mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein’s assistant, who pathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up
ntroduce each victim to Sarah Kellen, Epstein’s assistant, who pathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other fumishings. There were photographs o
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
phone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers a
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 Sarah Kellen and the Ex Post Facto

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSON
United States
LOCATION
Lake Worth
LOCATIONMichael J. Pike
PERSON
George W. Bush
PERSONKatherine W. Ezell
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON