EFTA00233329

effect on Defendant by tripling the presumptive minimum of damages available to a 
plaintiff, regardless of the actual damages suffered.8
C. As discussed above, 18 U.S.C. §2255 was enacted as part of the criminal 
statutory scheme to punish and penalize those who sexually exploit and abuse minors, 
and thus, the Ex Post Fact Clause prohibits a retroactive application of the 2006 amended 
version. Even if one were to argue that the statute is "civil" and the damages thereunder 
are "civil" in nature, under the analysis provided by the United States Supreme Court in 
Landgraf I USI Film Products 511 U.S. 244, 114 S.Ct. 1483 (1994), pertaining to civil 
statutes, not only is there no express intent by Congress to apply the new statute to past 
conduct, but also, the clear effect of retroactive application of the statute would be to 
increase the potential liability for past conduct from a minimum of $50,000 to $150,000, 
and thus in violation of the constitutional prohibitions against such application. As noted, 
18 U.S.C. §2255 is entitled "Civil remedy for personal injuries." Notwithstanding this 
label, the statute was enacted as part of the criminal statutory scheme to punish those who 
sexually exploit and abuse minors. 
Regardless of the actual damages suffered or proven 
by a minor, as long as a minor proves violation of a specified statutory criminal act under 
§2255 and personal injury, the defendant is held liable for the statutory imposed 
minimum. 
Notwithstanding the above legal analysis, in the recent case of Individual Known 
to Defendant As 08M1ST096.JPG and 08mist067.iog 
Falso, 2009 WI, 4807537 (N.D. 
N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York 
Plaintiff has attempted to allege 6 counts pursuant to 18 U.S.C. §2255. If it is Plaintiff's 
position that she is entitled to the minimum damage amount on each count, regardless of 
her actual damages, the absurdity of a retroactive application is more magnified. Clearly, 
the result is an unconstitutional increase in either a penalty or civil liability. 
20 
EFTA00233509

addressed the issue of whether §2255 is a civil or criminal statute for purposes of the 
constitutional prohibition against double jeopardy. 
The New York Court stated that 
"looking to the plain language of §2255(a), it is clear that the statutory intent was to 
provide a civil remedy. This is exemplified by the title ... and the fact that the statute 
aims to provide compensation to individuals who suffered personal injury as a result of 
criminal conduct against them." The New York Court in analyzing whether §2255 
violated the Constitutional prohibition against double jeopardy, concluded that although 
the behavior to which §2255 is criminal, it did not find that the "primary aim" was 
"retribution and deterrence." "The statute serves civil goals." The "primary aim" is "the 
compensation for personal injuries sustained as a result of criminal conduct." 
Therefore, because Jane Doe 103 has invoked the provisions of the criminal Non-
Prosecution Agreement (NPA) between EPSTEIN and USAO (see paragraphs 25 and 26 
of complaint), plaintiff cannot avoid the full protection of the rule of lenity and due 
process to which EPSTEIN is entitled in the context of these unique factual 
circumstances. 
Although there does not exist any definitive ruling of whether the damages 
awarded under §2255 are meant as criminal punishment or a civil damages award, 
Defendant is still entitled to a determination as a matter of law that the statute in effect at 
the time of the alleged criminal conduct applies. 
As explained by the Landgraf court, supra at 280, and at 1505,9
9 In Landaraf the United States Supreme Court affirmed the judgment of the Court of Appeals 
and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before 
the effective date of the Act. 'Ile Court determined that statutory text in question, §102, was 
subject to the presumption against statutory retroactivity. 
21 
EFTA00233510

When a case implicates a federal statute enacted after the events in suit, the court's 
first task is to determine whether Congress has expressly prescribed the statute's proper 
reach. If Congress has done so, of course, there is no need to resort to judicial default 
rules. When, however, the statute contains no such express command, the court must 
determine whether the new statute would have retroactive effect, i.e., whether it would 
impair rights a party possessed when he acted, increase a party's liability for past 
conduct, or impose new duties with respect to transactions already completed. if the 
statute would operate retroactively, our traditional presumption teaches that it does not 
govern absent clear congressional intent favoring such a result. 
Here, there is no clear expression of intent regarding the 2006 Act's application to 
conduct occurring well before its enactment. Clearly, however, as discussed in part B 
herein, the presumptive minimum amount of damages of $150,000 was enacted as a 
punishment or penalty upon those who sexually exploit and abuse minors. See discussion 
of House Bill Reports and Congressional background above herein. The amount triples 
the previous amount for which a defendant might be found liable, regardless of the 
amount of actual damages a plaintiff has suffered and proven. The new statute imposes a 
substantial increase in the monetary liability for past conduct. 
As stated in Landgraf, "the extent of a party's liability, in the civil context as well as 
the criminal, is an important legal consequence that cannot be ignored." Courts have 
consistently refused to apply a statute which substantially increases a party's liability to 
conduct occurring before the statute's enactment. Landgraf, supra at 284-85. Even if 
plaintiff were to argue that retroactive application of the new statute "would vindicate its 
purpose more fully," even that consideration is not enough to rebut the presumption 
against retroactivity. Id, at 285-86. "The presumption against statutory retroactivity is 
founded upon sound considerations of general policy and practice, and accords with long 
held and widely shared expectations about the usual operation of legislation." Id. 
Thus, Plaintiff's action should be dismissed and she should be required to plead her 
action under the applicable version of 18 U.S.C. §2255. 
22 
EFTA00233511

Motion For More Definite Statement and To Strike, Rule 12(e) and (f), F.R.C.P. 
As noted above, Plaintiff alleges that she was 17 year old high school student as 
of January, 2004, and that the alleged conduct involving EPSTEIN occurred "between 
approximately January 2004 and May 2005. Thus, Plaintiff had to be 18 (no longer a 
minor) by January of 2005. Under the principles of statutory construction, the language 
of §2255(a) is clear — "Any minor who is a victim of a violation of section ...of this title 
and who suffers personal injury as a result of such violation may sue in any appropriate 
United States District Court and shall recover the actual damages such minor sustains 
and the cost of the suit, including a reasonable attorney's fee. Any minor as described in 
the preceding sentence shall be deemed to have sustained damages of no less than 
$50,000 in value." 
As Plaintiff's date of birth is significant to her §2255 claim, she should be 
required to more definitely state her date of birth so that Defendant and this Court are 
able to determine precisely when she reached the age of majority. (The age of majority 
under both federal and state law is 18 years old. See 18 U.S.C. §2256(1), defining a 
"minor" as "any person under the age of eighteen years;" and §I.01, Definitions, Fla. 
Stat., defining "minor" to include "any person who has not attained the age of 18 years.") 
In addition, when Plaintiff reached the age of majority may impact her ability to even 
assert a §2255 claim. See §2255(b). 
To the extent that Plaintiff is relying on any alleged conduct that occurred after 
her 18 birthday as an element of her §2255 claim, such allegations should be stricken as 
immaterial and she should be required to more definitely state the dates of the alleged 
conduct. See Rule 12(0. Defendant also seeks to strike 1[110, I I, 12, 13, 14, 15, and 16, 
23 
EFTA00233512

of Plaintiff's Complaint as immaterial and impertinent. None of the allegations in those 
paragraphs specifically pertain to the Plaintiff. Not until ¶17 does Plaintiff assert 
allegations pertaining to her and the conduct of Defendant directly involving her. What 
EPSTEIN may or may not have allegedly done with respect to other alleged girls does 
not effect Plaintiff's claim brought pursuant to §2255. The allegations in ¶¶10-16 are not 
related to the elements of Plaintiff's §2255 claim and, thus, are required to be stricken. 
Conclusion 
Pursuant to the above, Plaintiff entire action is required to be dismissed. 
18 
U.S.C. §2255 allows for a single recovery of the actual damages sustained in proven; 
neither the "actual damages" sustained not the statutory minimum is subject to 
duplication or multiplication on a per violation or per count or per incident basis. Also, 
the statute in effect during the time of the alleged conduct applies, not the version as 
amended, effective July 27, 2006. Count VI is also required to be dismissed as it relies 
on a statutory predicate act that did not take effect until 2006. In addition, Plaintiff 
should be required to more definitely state her date of birth, and any conduct occurring 
after her 18th birthday should be stricken, and 1110 - 16 of the Complaint should also be 
stricken. 
WHEREFORE, Defendant requests that this Court dismiss the entire action 
against him, and further grant his motion for more definite statement and to strike. 
Robert D. Critton, Esq. 
Attorney for Defendant 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed 
with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is 
24 
EFTA00233513

being served this day on all counsel of record identified on the following Service List in 
the manner specified by CM/ECF on this 
day of 
 2010. 
Robert C. Josefsberg, Esq. 
Jack Alan Goldberger, Esq. 
Katherine W. Ezell, Es 
Atterbury Goldberger & Weiss, P.A. 
e 800 
ounse or amt 
12 
Counsel for Defendant Jeffity Epstein 
Respectfully submitted, 
By: 
ROBERT D. CRITFON, JR., ESQ. 
ounse or Pe en ant e rey pstein 
18 USCA 62255 (1999-July 26. 2006): 
PART I--CRIMES 
CHAPTER 110—SEXUAL EXPLOITATION AND OTHER ABUSE OF 
CHILDREN 
§ 2255. Civil remedy for personal injuries 
(a) Any minor who is a victim of a violation of section 2241(c), 2242, 
2243, 2251, 2251A. 2252, 2252A. 2260 2421 2422 or AZ 21 of this title 
25 
EFTA00233514

and who suffers personal injury as a result of such violation may sue in 
any appropriate United States District Court and shall recover the actual 
damages such minor sustains and the cost of the suit, including a 
reasonable attorney's fee. Any minor as described in the preceding 
sentence shall be deemed to have sustained damages of no less than 
$50,000 in value. 
(b) Any action commenced under this section shall be barred unless the 
complaint is filed within six years after the right of action first accrues or 
in the case of a person under a legal disability, not later than three years 
after the disability. 
CREDIT(S) 
(Added Pub.L. 99-500, Title I. 6 101(b)  [Title VII, § 703(a)), Oct. 18, 
1986, 100 Stat. 1783-75, and amended Pub.L. 99-591. Title I. § 101(b) 
[Title VII, § 703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314, 
Title VI. § 605 Oct. 30, 1998, 112 Stat. 2984.) 
18 U.S.C. 62255, as amended 2006. Effective July 27, 2006: 
PART I--CRIMES 
CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF 
CHILDREN 
§ 2255. Civil remedy for personal injuries 
(a) In general.--Any person who, while a minor, was a victim of a violation 
of section 2241(4 2242, 2243, 2251, 2251A 2252 2252A 2260, 2421, 
2422, or 2423 of this title and who suffers personal injury as a result of such 
violation, regardless of whether the injury occurred while such person was a 
minor, may sue in any appropriate United States District Court and shall 
recover the actual damages such person sustains and the cost of the suit, 
including a reasonable attorney's fee. Any person as described in the 
preceding sentence shall be deemed to have sustained damages of no less 
than $150,000 in value. 
(b) Statute of limitations.--Any action commenced under this section shall 
be barred unless the complaint is filed within six years after the right of 
action first accrues or in the case of a person under a legal disability, not later 
than three years after the disability. 
CREDIT(S) 
(Added Pub.L. 99-500. Title I. § 101(b) [Title VII, § 703(a)), Oct. 18, 1986, 
100 Stat. 1783-75, and amended Pub.L. 99-591. Title 1, 4 101(b) [Title VII, § 
703(a)), Oct. 30, 1986, 100 Stat. 3341-75; pub.L. 105-314. Title VI. 4 605 
26 
EFTA00233515

Oct. 30, 1998, 112 Stat. 2984; Pub.L. 109-248, Title VII, & 707(b). (c), July 
27, 2006, 120 Stat. 650.) 
2 Paragraphs 30, 34, 38, 43, 48, and 52 of Plaintiff's Complaint alleges: 
30. 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 has in the 
past suffered, and will in the future continue to suffer, physical injury, pain and 
suffering, emotional distress, psychological and/or psychiatric trauma, mental 
anguish, humiliation, confusion, embarrassment, loss of educational opportunities, 
loss of self-esteem, loss of dignity, invasion of her privacy, separation from her 
family, and other damages associated with Defendant manipulating and leading her 
into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical 
and psychological expenses. Plaintiff has suffered a loss of income, a loss of the 
capacity to earn income in the future, and a loss of the capacity to enjoy life. These 
injuries are permanent in nature, and Plaintiff will continue to suffer these losses in 
the future. 
The "Wherefore" clauses in each of the six counts are also identical — 
WHEREFORE Plaintiff demands judgment against Defendant for all damages 
available under 18 U.S.C. §2255, including, without limitation, actual and 
compensatory damages, attorney's fees, costs of suit, and such other relief this Court 
deems just and proper, and hereby demands trial by jury on all issues triable as of 
right by a jury. 
27 
EFTA00233516

EFTA00233517

- Not an Official Document 
Page 1 of 24 
Report SelectioriCriteria 
Case ID: 
Docket Start Date: 
Docket Ending Date: 
Case Description 
Case ID: 
Case Caption: 
Division: 
Filing Date: 
Court: 
Location: 
Jury: 
Type: 
Status: 
502006CF009454AXXXMB 
502006CF009454AXXXMB 
EPSTEIN, JEFFREY 
W - COLBATH 
Wednesday, July 19th, 2006 
CF -FELONY 
MB - MAIN BRANCH 
N-Non Jury 
CF -FELONY 
CLSD - CLOSED CASE 
Related Cases 
No related cases were found. 
Case Event Schedule 
Event 
Date/Time Room 
Location 
Judge/Commissioner 
CASE 
DISPOSITION 
MAIN 
BRANCH 
COURTROOM 
11F 
COLBATH, JUDGE JEFFREY 
CASE 
DISPOSITION 
MAIN 
BRANCH 
COURTROOM] 
11F 
COLBATH, JUDGE JEFFREY 
Case Parties 
Expn 
Date 
Type 
ID 
Name 
DEFENDANT 24167391 EPSTEIN, JEFFREY E.  Aliases: none 
3 
1 22-AUG- ATTORNEY 
ATTY 
MALINSKI, NORMAN 
2006 
Aliases: none 
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EFTA00233518

- Not an Official Document 
JUDGE 
Page 2 of 24 
COLBATH, JUDGE 
Aliases: none 
JEFFREY 
1 30-JUN-
2008 
ATTORNEY 
0262013 
GOLDBERGER ESQ, 
JACK A 
Aliases: none 
Docket Entries 
Docket 
Number 
Docket Type 
Book and Page No. 
Attached To: 
ZCAPS - CONVERSION 1ST CAPIAS 
ISS DATE 
Filing Date: 
17-JUL-2006 
-1 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
PerSchedule Tracking# 324329 
ZINFO - 
DATE 
CONVERSION INFO FILING 
Filing Date: 
19-JUL-2006 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
1 
JIDV - DOCKET HISTORY 
Filing Date: 
19-JUL-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
ARREST WARRANT DIVISION W ORDERED BY JUDGE KROLL 
ON 071706. ISSUED ON 071706. BOND SET PER SCHEDULE. 
2 
JIDV - DOCKET HISTORY 
Filing Date: 
19-JUL-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
INDICTMENT. 
2 A 
JIDV - DOCKET HISTORY 
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EFTA00233519

- Not an Official Document 
Page 3 of 24 
Filing Date: 
23-JUL-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
ARREST RECORD. 
3 
JIDV - DOCKET HISTORY 
Filing Date: 
25-JUL-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
CASH BOND. BOND POSTED ON 072306 RECEIPT: 00073142 
BOND AMT $3000 
---am• 
4 
I JIDV - DOCKET HISTORY 
-----ii
m,
Filing Date: 
27-JUL-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
NOTICE OF ARRAIGNMENT. 
5 
JIDV - DOCKET HISTORY 
Filing Date: 
16-AUG-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
NOTICE OF UNAVAILABILITY FILED BY L. BELOHLAVEK,ASA.BH 
6 
JIDV - DOCKET HISTORY 
Filing Date: 
22-AUG-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
PRAECIPE FOR APPEARANCE, WAIVER OF ARRAIGNMENT, 
PLEA OF NOT GUILTY AND REQUEST FOR JURY TRIAL FILED 
BY JACK GOLDBERGER. BH 
JIFM - MISD/FELONY 
HISTORY 
RECORD 
Filing Date: 
06-OCT-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
JIFM JUDICIAL INFORMATION FELONY RECORD WRITTEN NG 
PLEA: 08/22/06 CONFLICT Case: N DOWN-FILED To: FEE Case: N 
PTI Date: REOPEN: N PTI Reject: N Date: COMMENTS: None 
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EFTA00233520

- Not an Official Document 
Page 4 of 24 
FAHIS - 
HISTORY 
FELONY/MISD ARRAIGN 
Filing Date: 
06-OCT-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
X/JIFA FELONY-MISDEMEANOR 
IS EPSTEIN JEFFREY E LEGACY 
41673917332767 PRAECIPE AND 
082206 DATE: JUDGE: COURT: 
DEFENDANT PRESENT: PLEA: 
ARRAIGNMENT PASSED TO: DATE: 
RELEASED, FAILURE OF STATE 
!COMMENTS: None 
ARRAIGNMENT RECORD DEF 
CASE NUMBER: 
WAIVER FILED BY: DATE: 
DEFENSE ATTY: PD APPT: 
ADVISED OF RIGHTS: 
TIME: COURT: DEFENDANT 
TO FILE DATE: PTI DATE: 
CALHS - CALENDAR HISTORY 
Filing Date: 
06-OCT-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
08/25/06 0845 CLDR= F DIV= AW 
082506 RESET TO 0000 DIV: REMARKS: 
PRAECIPE FOR APPEARANCE 
FILE TO JUDGE FOR DATE (D/ARS) 
ARRAIGNMENT DELETED- ON
(CR-DAMES)-, 
& WAIVER FILED ON 02206-SEND 
7 
JDN - JUDICIAL NOTES 
Filing Date: 
16-NOV-2006 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
SETTING CASE FOR CASE DISPOSITION ON 12/8/06 @ 8:30 A.M. 
EVSCH 
SCHEDULED 
- HEARING EVENT 
Filing Date: 
30-NOV-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
8 
NOH - NOTICE OF HEARING 
Filing Date: 
04-DEC-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
Docket entry for the letter produced 
by LPRATTS. 
from CSAEOUT on 04-DEC-2006 
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EFTA00233521

- Not an Official Document 
Page 5 of 24 
EVSCH - HEARING EVENT 
SCHEDULED 
Filing Date: 
07-DEC-2006 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
EVCON - EVENT CONTINUED 
Filing Date: 
Filing Party: 
Disposition Amount: 
Docket Text: 
07 DEC-2006 
EPSTEIN, JEFFREY E 
AGREED ORDER CONTINUING CASE DISPO.
9 
WST - WAIVER OF SPEEDY TRIAL 
Filing Date: 
I07-DEC-2006 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
10 
Filing Date: 
FILED BY JACK GOLDBERGER (D/ARS)
AGOR - AGREED ORDER 
07-DEC-2006 
Filing Party: 
EPSTEIN JEFFREY E 
Disposition Amount: 
Docket Text: 
11 
(JUDGE MCSORLEY) CONTINUING CASE DISPO PRESENTLY 
SCHEDULED 08-DEC AT 0830AM TO 08-MARCH-2007 AT 
0830AM. 
RMAL - RETURNED MAIL 
Filing Date: 
Filing Party: 
Disposition Amount: 
Docket Text: 
1 
11-DEC-2006 
EPSTEIN. JEFFREY E 
UNABLE TO FORWARD 
NOUN - NOTICE OF UNAVAILABILITY 
Filing Date: 
21-FEB-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
07-18 THRU 7-20 FILED BY ASA 
EVSCH - HEARING EVENT 
SCHEDULED 
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EFTA00233522

- Not an Official Document 
Page 6 of 24 
Filing Date: 
05-MR-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
EVRST - EVENT RESET 
Filing Date: 
05-MAR-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
AGREED ORDER CONTINUING CASE DISPO 
13 
AGOR - AGREED ORDER 
Filing Date: 
05-MAR-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
IRisposition Amount: 
Docket Text: 
I(JUDGE MCSORLEY) CONTINUING CASE DISPO PREVIOUSLY-
1 
SET FOR 08-MAR-2007 AND RESETTING FOR CASE DISPO ON 
16-MAY-2007 AT 0830AM. 
14 
NOH - NOTICE OF HEARING 
Filing Date: 
07-MAR-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
Docket entry for the letter produced from CSAEOUT on 07-MAR-
2007 by DFELDER. 
15 
NOUN - NOTICE OF UNAVAILABILITY 
Filing Date: 
12-APR-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
FILED BY ASA 4-30 THRU 05-04 
EVCON - EVENT CONTINUED 
Filing Date: 
11-MAY-2007 
Filing Party: 
1 EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
AGREED ORDER CONTINUING 
16 
AGOR - AGREED ORDER 
Filing Date: 
11-MAY-2007 
i 
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EFTA00233523

- Not an Official Document 
Page 7 of 24 
Filing Party: 
'EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE MCSORLEY) CONTINUING CASE DISPO FROM 16-MAY-
2007 TO 16-NOV-2007 AT 0830AM.
EVSCH 
SCHEDULED 
HEARING EVENT 
Filing Date: 
14-MAY-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
!none. 
EVSCH 
SCHEDULED 
- HEARING EVENT 
Filing Date: 
15-MAY-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
fipone. 
EVCAN 
CANCELLED/SETTLED 
- EVENT 
Filing Date: 
15-MAY-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CANCEL 051607/ADD TO CALENDAR 111607-PER J.A NOTE 
FILED 051507 (D/ARS) 
17 
f JDN - JUDICIAL NOTES 
Filing Date: 
15-MAY-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
FROM J.A.CANCEL FROM 051607/ADD TO CALENDAR 111607, 
0830AM FOR CASE DISPOSITION FILED (D/ARS) 
18 
I NOH - NOTICE OF HEARING 
Filing Date: 
']
16-MAY-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
Docket entry for the letter produced from CSAEOUT on 16-MAY-
2007 by DFELDER. 
19 
NOUN - NOTICE OF UNAVAILABILITY] 
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EFTA00233524

- Not an Official Document 
Page 8 of 24 
Filing Date: 
25-JUL-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
8-22 THRU 24 FILED BY ASA 
20 
NOUN - NOTICE OF UNAVAILABILITY 
Filing Date: 
08-AUG-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
FILED BY ASA 
21 
I NOUN - NOTICE OF UNAVAILABILITY 
Filing Date: 
12-SEP-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
9-18 THRU 20 FILED BY ASA 
22 
NOUN - NOTICE OF UNAVAILABILITY 
Filing Date: 
01-OCT-2007 
Filing Party: 
EPSTEIN JEFFREY E 
Disposition Amount: 
Docket Text: 
10-09 THRU 12 FILED BY ASA 
EVCAN 
CANCELLED/SETTLED 
- EVENT 
30-OCT-2007 
Filing Date: 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
EVSCH 
SCHEDULED 
HEARING EVENT 
Filing Date: 
30-OCT-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
23 
AGOR - AGREED ORDER 
Filing Date: 
30-OCT-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
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EFTA00233525

- Not an Official Document 
Page 9 of 24 
'Disposition Amount: 
Docket Text: 
(JUDGE MCSORLEY) SCHEDULING CASE FOR TRIAL - 
CANCELLING CASE FOR 11/16/07 @ 8:30 AM FOR CASE 
DISPOSITION AND SETTING FOR 1/07/08 @ 9:00 AM FOR JURY 
TRIAL 
24 
JJDN - JUDICIAL NOTES 
Filing Date: 
30-OCT-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CASE CANCELLED FOR 11/16/07 @ 8:30 AM FOR CASE DISPO 
AND 11/20/07 @ 8:30 AM FOR PLEA CONFERENCE ( NOT 
SCHEDULED) 
25 
NOH - NOTICE OF HEARING 
Filing Date: 
06-NOV-2007 
Filing Party: 
i 
Disposition Amount: 
Text: 
Docket entry for the letter produced from CSAEOUT on 06-NOV-
2007
Docket 
 by DFELDER. 
26 
i NOH - NOTICE OF HEARING 
Filing Date: 
10-DEC-2007 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Tex • 
SETTING CASE FOR 1/04/08 FOR PLEA CONFERENCE - FILED 
BY J. GOLBERGER 
EVSCH 
SCHEDULED 
HEARING EVENT 
Filing Date: 
11-DEC-2007 
Filing Party: 
Disposition Amount: 
Docket Text: 
'none. 
27 
MOT - MOTION 
Filing Date: 
02-JAN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
i
AGREED MOTION TO CONTINUE TRIAL - FILED BY J. 
GOLDBERGER 
I 
I 
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Page 10 of 24 
EVSCH - HEARING EVENT 
SCHEDULED 
Filing Date: 
03-JAN-2008 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
EVCAN - EVENT 
CANCELLED/SETTLED 
Filing Date: 
03-JAN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
EVCAN - EVENT 
CANCELLED/SETTLED 
Filing Date: 
03-JAN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
28 
LTR LETTER 
Filing Date: 
I03-JAN-2008 
Filing Party: 
IEPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
29 
Filing Date: 
[FIling Party: 
Disposition Amount: 
TO JUDGE MCSORLEY FROM JACK A. GOLDBERGER RE: 
AGREED MOTION TO CONTINUE. 
MOT - MOTION 
03-JAN-2008 
Docket Text: 
EPSTEIN, JEFFREY E 
AGREED MOTION TO CONTINUE TRIAL FILED BY JACK A. 
GOLDBERGER. 
30 
jAGOR - AGREED ORDER 
Filing Date: 
03-JAN-2008 
Filing Party: 
Disposition Amount: 
EPSTEIN, JEFFREY E 
(JUDGE MCSORLEY) CONTINUING TRIAL FROM 07-JAN-2008, 
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- Not an Official Document 
Page 11 of 24 
Docket Text: 
CANCELLING PLEA CONFERENCE 
SETTING CASE FOR A STATUS 
08:30AM. 
ON 04-JAN-2008 AND 
CHECK ON 10-MAR-2008 AT 
31 
NOH - NOTICE OF HEARING 
Filing Date: 
28-JAN-2008 
Filing Party:
1 
Disposition Amount: 
Docket Text: 
Docket entry for the letter produced 
by VBUCKLEY. 
from CSAEOUT on 28-JAN-2008 
32 
IDEPO - DEPOSITION 
Filing Date: 
31-JAN-2008 
Filing Party: 
EPSTEIN JEFFREY E 
Disposition Amount: 
Docket Text: 
(NOTICE OF) FILED BY J. GOLDBERGER 
32 A 
I MEP() - 
ORDER 
MOTION FOR PROTECTIVE 
Filing Date: 
06-FEB-2008 
I 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
FILED BY THEODORE LEOPOLD 
33 
MFPO - 
ORDER 
MOTION FOR PROTECTIVE 
Filing Date: 
07-FEB-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
FILED BY THEODORE LEOPOLD, ESQ. 
34 
ORD - ORDER 
Filing Date: 
07-FEB-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE MCSORLEY) ATTORNEY 
IN WRITING TO SAID MOTION 
THIS ORDER, COURTESY COPY 
SUBMITTED TO UNDERSIGNED'S 
FOR DEFT SHALL RESPOND 
W/IN 5 DAYS FROM DATE OF 
OF SAME SHALL BE 
CHAMBERS. 
34 A 
IRESP - RESPONSE TO: 
Filing Date: 
08-FEB-2008 
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EFTA00233528