EFTA00207722.txt

"criminal Non-Prosecution Agreement (NPA) between EPSTEIN and USAO"

"draft motion authored by his civil counsel Robert Critton"

"JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant"

"JEFFERY EPSTEIN, Defendant"

"March 29, 2010 ... Jeff Sloman, Esq. ... Your truly, MARTIN WEINBERG, ESQ."

"Robert D. Critton, Esq. Attorney for Defendant"

"MICHAEL J. PIKE, ESQ. ... (Counsel for Defendant Jeffrey Epstein)"

"Robert C. Josefsberg, Esq. ... Counsel for Plaintiff"

"Katherine W. Ezell, Esq. ... Counsel for Plaintiff"

"Jack Alan Goldberger, Esq. ... Counsel for Plaintiff"

"As a direct and proximate result of the offenses enumerated in 18 U.S.C. §2255 being committed against the then minor Plaintiff by Defendant"

"As a direct and proximate result of the offenses enumerated in 18 U.S.C. §2255 being committed against the then minor Plaintiff by Defendant"

"Plaintiff's Complaint alleges that Defendant's conduct occurred during the time period from the age of 17, January 2004 until approximately May 2005"

"Defendant's position that the text of 18 U.S.C. §2255 does not allow a Plaintiff to pursue the recovery of actual damages"

"Jane Doe 103 has invoked the provisions of the criminal Non-Prosecution Agreement (NPA) between EPSTEIN and USAO"

"the 2006 version of 18 U.S.C. §2255 to acts that occurred prior to its effective date would have a detrimental and punitive effect on Defendant"

"Defendant "sexually abused and/or battered and/or exploited Plaintiff at least 100 times between January 2004 and May 2005.""

"Plaintiff "was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure underage females.""

"one of the minor victims Defendant paid to procure underage females"

"Jane Doe 103 was a victim of the commission of one of the enumerated predicate violations as required"

"The letter is from the firm Black Srebnick Kornspan & Stumpf regarding Jeffrey Epstein's legal deadlines."

"The letter is from the firm Black Srebnick Kornspan & Stumpf regarding Jeffrey Epstein's legal deadlines."

"The letter is from the firm Black Srebnick Kornspan & Stumpf regarding Jeffrey Epstein's legal deadlines."

"The letter is from the firm Black Srebnick Kornspan & Stumpf regarding Jeffrey Epstein's legal deadlines."

"ROY BIACK ... Black. Srebnick. Kornspan & Stumpf. I'.A."

"Plaintiff alleges that she was 17 year old high school student as of January, 2004, and that the alleged conduct involving EPSTEIN occurred 'between a"

"Plaintiff's Complaint alleges that Defendant's conduct occurred during the time period from the age of 17, January 2004 until approximately May 2005"

"should Plaintiff prove any violation of the specified criminal statutes and that she suffered personal injury and sustained actual damages"

"support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause"

"EPSTEIN will not contest the allegation that he committed at least one predicate offense as alleged by Jane Doe 103"

"ROBERT D. CRITTON, JR., ESQ. ... BURMAN, CRITTON, LUTHER & COLEMAN"

"MICHAEL J. PIKE, ESQ. ... BURMAN, CRITTON, LUTHER & COLEMAN"