4
Shared Docs
4
Same-Page
4 / 4
Mentions
e deposition testimony of Plaintiff attached to her response details JANE DOE's version of what occurred between EPSTEIN and her when she was at his Palm Beach mansion. See depo. pages 539 — 600. JANE DOE, when examined by her own attorney, testified that she was brought to the mansion by i on her first vi
endant's Motion, Discussion of Law, Part I, pp. 8-19. 8. Like EPSTEIN, Plaintiff also cites on the United States Supreme Court case of Landgraf v. USI Film Products , 511 U.S. 244, 280, (1994), as a landmark decision in determining whether or not a statute violates constitutional principles against retroactivi
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
t that the statute is to apply retroactively, and, accordingly, the statute in effect during the time of the alleged conduct is to apply. Landgraf USI Film Products supra, at 1493, ("A statement that a statute will become effective on a certain date does not even arguably suggest that it has any application to
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
t that the statute is to apply retroactively, and, accordingly, the statute in effect during the time of the alleged conduct is to apply. landgraf USI Film Products supra, at 1493, ("A statement that a statute will become effective on a certain date does not even arguably suggest that it has any application to
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
t that the statute is to apply retroactively, and, accordingly, the statute in effect during the time of the alleged conduct is to apply. Landgraf USI Film Products supra, at 1493, ("A statement that a statute will become effective on a certain date does not even arguably suggest that it has any application to
Entities connected to both Palm Beach and USI Film Products

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Eric Holder
PERSON
Lesley Groff
PERSONFBI
ORGANIZATIONJane Doe
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Prince Andrew
PERSONMaria Farmer
PERSON
John F. Kennedy
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSON