Epstein Secrets

f Justice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LL

stice Washington, D.C. 20530 June 23, 2008 Jay Lefkowitz„ Esq. Kenneth Starr, Esq. Kirkland and Ellis LL

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

ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

s, which is consistent with applicable law discussed more fully below herein. 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 Landgraf I. USI Film Products 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994

for itself." That the provisions of ¶8 are "far from simple" is illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel, Jay Lefkovvitz, who repeatedly advised Mr. Acosta, by letter, that he considered the waiver of liability to be limited to those who agreed to damages, and was ina

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

s, which is consistent with applicable law discussed more fully below herein. 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 Landgraf I. USI Film Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (199

Granting Motion for Limited Appearance of Jay P. Lefkowitz) (Critton, Robert) (Entered: 05/21/2009) 05/21/

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 (199