n, but it was a damages remedy that already existed at the time of Defendant EPSTEIN's commission of the acts against the minor. Hence, here, unlike Landsgraf, there was an existing civil remedy prior to Defendant EPSTEIN's commission of the acts against the minor Plaintiff, and there continues to be such

Plaintiff has not been able to 12 EFTA00222884 Case 9:09-cv-80469-KAM Document 36 Entered on FLSD Docket 06/12/2009 Page 13 of 19 dissent in Landsgraf, there is no vested right to break the law." Bottom line is, a motion to dismiss a claim is not the correct procedural mechanism to determine the r

y not present here, and the record is devoid of any factual material that would support such a conclusion.1° As Justice Blackmun said in dissent in Landsgraf, there is no vested right to break the law." Bottom line is, a motion to dismiss a claim is not the correct procedural mechanism to determine the r

y not present here, and the record is devoid of any factual material that would support such a conclusion.10 As Justice Blackmun said in dissent in Landsgraf, there is no vested right to break the law." Bottom line is, a motion to dismiss a claim is not the correct procedural mechanism to determine the r