EFTA00212960.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"

"Congress did not intend Masha's Law to apply retroactively"

"Congress provided that offenders must register"

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

"Case 9:09-cv-80591-KAM... Count One must be dismissed because it fails to provide factual allegations that, if true, would show that Plaintiff is the "

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

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

"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"

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

"Defendant's mansion"

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

"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"

"Retroactively Applying Masha's Law Impermissibly Would Revive Defendant's Exposure"

"Case 9:09-cv-80591-KAM... retroactive application would revive Defendant's exposure to penalties"

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

"Defendant's plea to two single-count charges under Florida law... does not remotely establish that Defendant committed any offense against Plaintiff"

"Plaintiff was first brought to Defendant's mansion"

"Defendant or an authorized agent would call and alert Defendant's assistants"

"Plaintiff herself is the victim of such an offense"

"Plaintiff "was recruited by one of Defendant's agents to give Defendant a massage for compensation,""

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

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

"Case 9:09-cv-80591-KAM ... the FAC alleges only that Defendant ... may have taken lewd photographs of Plaintiff"

"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"

"Defendant's exposure to penalties for his alleged crimes... Applying Masha's Law thereby would revive Defendant's exposure"

"statement of Sen. Grassley ("(T]he sanctions provided for in my bill, such as ... the amended civil remedy section... provide much needed criminal enf"

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

"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. § 2423(b)"

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

"Plaintiff "was recruited by one of Defendant's agents""

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

"a topless woman "with dark hair [and] an accent ... tried to coax Plaintiff to remove her shirt.""

"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."

"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"

"The Eleventh Circuit's decision in United States v. Siegel... is virtually on point"