Epstein Secrets

) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual a

in Santos, supra, at 2025: ... The rule of lenity requires ambiguous criminal laws to be interpreted in favor of the defendants subjected to them. See United States v. Gradwell, 243 U.S. 476, 485, 37 S.Ct. 407, 61 L.Ed. 857 (1917); AfcBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931); U

al. Aug. 19, 2009); U.S. v. Monk, 2009 WL 2567831, fn. 1 (ED. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, fill (E.D. Cal. Aug. 18 2009). 18 U.S.C.A. §2255 - Civil Remedy for Personal Injuries, creates a federal cause of action or "civil remedy" for a minor victim of sexual, abuse, molestation and

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S-C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

at Mr. Epstein could "agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United Stated, Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agr

, judicial restraint, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States'. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2) a

victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defe

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, N.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

, judicial restraint, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2)

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

, judicial restraint, and the rule of lenity applied in construing a statute, Defendant's position as to the meaning of the statute would prevail. See United States v. Santos 128 S.Ct. 2020, 2025 (2008). As summarized by the United States Supreme Court in Santos, supra, at 2025: 5 See argument in sections (2)

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

ired by ¶8 of the NPA? 6. Whether damages are to be awarded based on injury to a plaintiff or based on the number of separately proven claims, see United States'. Raker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the contention that damages were to be allocated per violation? We are not askin

s a victim of one or more offenses enumerated in 18 . § 2255, and, as such, asserts a cause of action against Defendant pursuant to this Section of the United States Code. 30. As a direct and proximate result of the offenses enumerated in 18 . § 2255 being committed against the then minor Plaintiff by Defendan

ator Punishment Act of 1998;" House Report No. 105-557, 11, 1998 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 §2255 is included, is described as "the most comprehensive package of new crimes and increased penalties e

held that $1,000 minimum is available only to plaintiffs who suffer actual damages, and Doe had not raised a triable issue of fact of such damages. The United States Supreme Court, using a straightforward textual analysis, agreed with the Fourth Circuit Court of Appeal. §2255 is also limited to those plaintiffs w

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penal

n FLSD Docket 05/06/2009 Page 4 of 29 Jane Doe II v. Epstein, et al Page 4 presumptively competent to adjudicate claims arising under the laws of the United States.'" Id, and cases cited therein. Significantly, in order to give federal courts exclusive jurisdiction over a federal cause of action, Congress must,

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penal