This document is a legal response filed by Plaintiff C.L. opposing Jeffrey Epstein's motion to dismiss Count III of her complaint. The core legal argument concerns whether the Adam Walsh Act (2006) can be applied retroactively to Epstein's conduct; the Plaintiff argues it provides a civil, non-punitive remedy and thus does not violate the Ex Post Facto clause. The document also graphically describes Epstein's 'systematic' child exploitation enterprise, involving at least three assistants who recruited, groomed, and paid minor girls, which Epstein sought to strike from the record.
This document is a page from an Office of Professional Responsibility (OPR) report analyzing the decision to resolve a federal investigation against Epstein with a state plea deal. It details the rationale behind the decision, citing concerns about the case's viability and state jurisdiction, and specifically recounts communications from June and July 2007 between the U.S. Attorney's Office (USAO) and Epstein's defense team regarding the proposed state resolution.
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