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ined under this title, imprisoned not more than 15 years, or both. (b) Of a ward.--Whoever, in the special maritime and territorial jurisdiction of the United States or in a Federal prison, or in any prison, institution, or facility in which persons are held in custody by direction of or pursuant to a contract or
, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail over Plaintiffs view. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: ... The rule of lenity requires
E, ESQ. Florida Bar #617296 BURMAN CRITTON, JR., ESQ. 4162 RITT • k ■ • s llen COLEMAN (Counsel for Defendant Jeffrey Epstein) ' ENDNOTE: U.S.C.A. - Title 18. Crimes and Criminal Procedure, Chapter 109A. Sexual Abuse §2241. Aggravated Sexual Abuse. (c) With children.--Whoever crosses a State
ied in 18 U.S.C. §2255 in order to state a cause of action. Thus, Counts I through XXX against EPSTEIN are required to be dismissed. Rule 12(b)(6), Fla.R.Civ.P. (2) Count XXXI — Sexual Battery is also required to be dismissed for failure to state a cause of action as Plaintiff has failed to allege the re
luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi
s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State
effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d
ation of health care providers telephone numbers used by Epstein and his employees general information based on Florida Standard Interrogatories, Fla.R.Civ.P. Form 2, nos. 7, 10, 12 I, 2, 3, 4, 5, 6, 10, 17 7 8 II, 12 13, 14, 164 These Interrogatories, on their face, do not infringe upon or otherwi
effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d
ation of health care providers telephone numbers used by Epstein and his employees general information based on Florida Standard Interrogatories, Fla.R.Civ.P. Form 2, nos. 7, 10, 12 I, 2, 3, 4, 5, 6, 10, 17 7 8 II, 12 13, 14, 164 These Interrogatories, on their face, do not infringe upon or otherwi
ined under this title, imprisoned not more than 15 years, or both. (b) Of a ward.--Whoever, in the special maritime and territorial jurisdiction of the United States or in a Federal prison, or in any prison, institution, or facility in which persons are held in custody by direction of or pursuant to a contract or
ailed to state a cause of action under either common or statutory law, and thus, Count I against EPSTEIN is required to be dismissed. Rule 12(b)(6), Fla.R.Civ.P. Count I alleges in part that while Plaintiff was a minor, beginning when she was 14 — 6. On numerous occasions ..., JEFFREY EPSTEIN intentionall
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