Epstein Secrets

e and relatively economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these girls, and then gave them money. Podhurst Orseck, P.A. 2 25 West Flagler Street. Suite 800. Miami, FL 33130, Miami 305.358.2800 Fax 305358.2382 • Fat Lauderdale 954.463.4316 www.podhurst.com EFT

tatute 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 new provisions of the Civil Rights Act of 1991 to conduct occurring before the e

te, 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: 3 See argument in sections (2) and (3) that follow which represent the predicate for the rule of lenity issue discussed

61-832-7137 F [email protected] Counsel for Plaint/ff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 14 Case 9:08-cv-80119-KAM Document 391 Entered on FLSD Docket 11/03/2009 Page 15

ein to walk a thin line with regard to "surrender[ing] the very protection which the privilege is designed to guarantee." Hoffman, 341 U.S. at 479. The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege also encompasses the 10 Case 9:08-cv-80119-KAM Document 391 Entered on FLSD D

61-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 Case 9:08-cv-80119-KAM Document 151 Entered on FLSD

in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege includes the circumstances as here "the act of producing documents in response to a

fied on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250

e, 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) and (3) that follow which represent the predicate for the rule of lenity issue discussed

fied on the following Service List in the manner specified by CM/ECF on this day of , 2010. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] [email protected] Counsel fo

e, 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) and (3) that follow which represent the predicate for the rule of lenity issue discussed

ro M. Garcia, Esq. Garcia Law Firm, P.A. Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. Bruce Reinhart, Esq. Counsel for Plaintiffs in Related Cases EFTA00221951 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07)

ion and freeze them so that they may be preserved to satisfy a potential judgment." a at 1527. The court went on to cite an oft- quoted passage from the United States Supreme Court in De Beers Consol. Mines, Ltd. v. United States, 325 U.S. 212, 221 (1945): To sustain the challenged order would create a precedent of sweeping e