Payment received by Plaintiff documented in Endnote 2
This document is a Motion to Dismiss filed by Jeffrey Epstein's defense team in the U.S. District Court for the Southern District of Florida on May 6, 2009, against Plaintiff Jane Doe II. The defense argues that the federal case should be dismissed because a nearly identical state case was filed 10 months prior, and because the plaintiff is improperly applying a 2006 amendment to 18 U.S.C. ยง2255 retroactively to conduct alleged to have occurred between 2003 and 2005, thereby violating the Ex Post Facto clause. Additionally, the motion argues that the statute does not allow for multiplying damages per incident and that the plaintiff failed to allege the necessary interstate commerce elements required for federal jurisdiction.
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