EFTA00212893.txt

"JANE DOE No. 101, Plaintiff, v. JEFFREY EPSTEIN, Defendant."

"JEFFREY EPSTEIN, Defendant."

"Senator Kerry—the author of Masha's Law"

"Masha's Law was enacted as part of the Adam Walsh Act"

"The centerpiece of that Act was an expanded sex-offender registry ("SORNA")"

"Defendant's exposure to penalties that previously had become barred as a matter of law"

"Defendant's Plea To Certain State-Law Offenses Is Insufficient To Authorize Suit Under 18 U.S.C. § 2255"

"must admit liability unto Plaintiff"

"Defendant's mansion in or about the spring of 2003"

"Plaintiff is the victim of a violation of § 2242(b)"

"Case 9:09-cv-80591-KAM... Defendant"

"Defendant is a successful businessman... Case 9:09-cv-80591-KAM"

"Plaintiff herself is the victim of such an offense... Case 9:09-cv-80591-KAM"

"Defendant has never been convicted of an offense under 18 U.S.C. § 2422(b)"

"Plaintiff has not alleged... that Defendant has been convicted of committing a predicate federal criminal offense against her"

"Counsel for Defendant Jeffrey Epstein... Case 9:09-cv-80591-KAM"

"Jack Alan Goldberger, Esq... Counsel for Defendant Jeffrey Epstein"

"Robert D. Critton... Counsel for Defendant Jeffrey Epstein"

"Michael J. Pike, Esq... Counsel for Defendant Jeffrey Epstein"

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

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

"Plaintiff was first brought to Defendant's mansion in or about the spring of 2003"

"Plaintiff was first brought to Defendant's mansion"

"she openly admits that she was 17 years-old in 2003... when she filed this case in April 2009"

"Because Plaintiff was 17 when the predicate offenses allegedly were committed, she could have sought the statutory penalty"

"Defendant's exposure to penalties for his alleged crimes"

"the defendant in Palm Beach County did solicit or procure someone to commit pros[titution]"

"Defendant's assistants shortly before or after he arrived at his Palm Beach residence"

"Plaintiff 'was recruited by one of Defendant's agents to give Defendant a massage for compensation,' and that Defendant's agent 'drove [Plaintiff] to "

"Defendant's mansion"

"drove [Plaintiff] to [Defendant's] mansion"

"the MC does not remotely allege that Plaintiff is a victim of a violation of §§ 2252(aX1) or 2252A(aX1)"

"Masha's Law cannot lawfully be applied in this case... revive Defendant's exposure to penalties"

"Defendant entered the room, and eventually asked Plaintiff to massage his buttocks. He then allegedly 'ordered Plaintiff to remove her clothes,' 'bega"

"Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old."

"Because Plaintiff was 17 when the predicate offenses allegedly were committed"

"Plaintiff was first brought to Defendant's mansion in or about the spring of 2003... Defendant thereafter lured [Plaintiff] to [his home] on at least "

"the FAC thus fails to allege facts that, even if true, would establish that Defendant engaged in the sort of sex tourism that violates 18 U.S.C. § 242"

"Count III of the FAC asserts a cause of action... predicated on allegations that Defendant violated 18 U.S.C. § 2251"

"one of Defendant's agents"

"She allegedly was paid $200, and then driven away by Defendant's agent."

"Robert C. Josefsberg, Esq... Podhurst Orseck, P.A."

"Jack Alan Goldberger, Esq... Atterbury Goldberger & Weiss, P.A."

"Robert D. Critton... Burman Critton Luther & Coleman, P.A."

"retroactively applying Masha's Law in a manner that would revive Defendant's exposure to statutory penalties"

"she was "lured" to the mansion "on at least one and perhaps two other occasions in the spring and/or summer of 2003""

"Defendant's assistants later "would seek out economically disadvantaged and underage girls from West Palm Beach""

"the FAC does not remotely allege that his dominant motive for travel was to engage in illicit sexual acts (much less that he traveled with the dominan"