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personal matters and contacts to which he attends in Florida. For example, beginning in 2002, Mr. Epstein visited his mother nearly every weekend in Palm Beach until she passed away in April, 2004. 5 As previously set forth herein, and as more fully explained in other submissions related to this case, the r
olations of 18 U.S.C. §§ 1591, 2422(b) and 2423(b). Since the limited review conducted by CEOS, two Supreme Court decisions—one authored by Justice Scalia and the other by Justice Thomas--have revitalized the bedrock principles that federal criminal statutes must be narrowly construed, that they may no
ds. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and
der the law that existed when the con uct took place has timeless and universal appeal." Kaiser Alum. & trt Corp . B mo 494 U.S. 827, 855 (1990) (Scalia, J., concurring). Id. at 265 (footnote omitted). Courts therefore apply the statute in effect at the time of the underlying conduct unless there is
elephonically by Sarah LNU to make arrangements to go to Epstein's residence. Sarah LNU would call a day or two ahead of their scheduled arrival in Palm Beach. Epstein also called Rivera occasionally from his Palm Beach residence. Another female, named Natasha, Natalia or Nadia LNU, who was described as t
s should be proven to a jury in the same manner as the other elements of the crint Writing•for the majority in Sattazahn . Pennsylvania, Justice Scalia explained at before Ring, "capital-sentencing proceedings were un- derstood to be just that: sentencing pro- ceedings. " 537 U.S. 101, 110, 123 S.C
Entities connected to both Palm Beach and Scalia

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
New York
LOCATION
Marc Rich
PERSON
New York City
LOCATION
Donald Trump
PERSONJane Doe
PERSON
Lesley Groff
PERSON
Bill Clinton
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON