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o related to the indictment. On September 7, 2007, Epstein's attorneys met with the U.S. Attorney, Drew Oosterbaan, Jeff Sloman, John McMillan, and I. Ken Starr presented federalism arguments, urging deferral to state prosecution. When those arguments failed, Epstein's attorneys slated that he wanted to enga
RNEY 3 Case No. 08-80736-CV-MARRA P-011819 EFTA00192865 U.S. Department of Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LLP 777 South Figueroa Street Los Angeles, CA 90017 Gentlemen: This Office has completed a thorough review of the U.S.
sterbaan, Jeff Sloman, John McMillan, and I. Ken Starr presented federalism arguments, urging deferral t
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,
is not inconsistent with our belief that the required scope of waiver was to a predicate offense in the singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2 ("were Mr. Epstein convicted at trial, the plaintiff-victims would not have to show that a violation of an enumeration secti
e singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2 ("were Mr. Epstein convic
, 153 F.3d 1256 (1 l'h Cir. 1998); U.S... Edwards 162 F.3d 87 (3d Cir. 1998); and generally, Calder Bull 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798). The United States Constitution provides that In], Bill of Attainder or ex post facto Law shall be passed" by Congress. U.S. Const. art. I,
irected to Congress (§ 9, cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as applicable only to penal legislation. See Calder'. Bull, 3 Dall. 386, 390-391, 1 L.Ed. 648 (1798) (opinion of Chase, J.). These provisions demonstrate that retroactive statutes raise particular co
is not inconsistent with our belief that the required scope of waiver was to a predicate offense in the singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2 ("were Mr. Epstein convicted at trial, the plaintiff-victims would not have to show that a violation of an enumeration secti
est that the plaintiff was injured, see United Stated, Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agrees that Mr. Epstein can contest the injury element under the NPA ("were Mr. Epstein convicted at tr
el, 153 F.3d 1256 (11th Cir. 1998); U.S. Edwards 162 F.3d 87 (3d Cir. 1998); and generally, Calder 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
Entities connected to both Ken Starr and Calder

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
Jay Lefkowitz
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United States
LOCATIONJack Goldberger
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONRoy Black
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George W. Bush
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Bradley Edwards
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Bill Clinton
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Kenneth Marra
PERSONGerald Lefcourt
PERSONJane Doe
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONMartin Weinberg
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Donald Trump
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