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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
ional principles against retroactivity. Further supporting the argument set forth by Defendant, Plaintiff describes the following language from the Landgraf decision as "a two step process for resolving retroactivity issues," (Response, p. 13): When a case implicates a federal statute enacted after the
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 on her first visi
th by Defendant, Plaintiff describes EFTA00611594 Jane Doe v. Epstein Case No. 08-CV-80893-Marra-Johnson Page 6 the following language from the Landgraf decision as "a two step process for resolving retroactivity issues," (Response, p. 13): When a case implicates a federal statute enacted after the
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
entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply
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
entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landaraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply
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
entitled to a determination as a matter of law that the statute in effect at the time of the alleged criminal conduct applies. As explained by the Landgraf court, supra at 280, and at 1505,9 9 In Landaraf the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply
Entities connected to both Palm Beach and Landgraf

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