Epstein Secrets

original). However, by phrasing that principle in the permissive way—that the absence of indictment "=" be strong evidence (emphasis supplied)—the Legislature conveyed nothing more than the simple fact that there were circumstances under which the absence of formal charges would, in fact, cast doubt on th

mplaint about either the form or content of that determination. CONCLUSION The judgment of conviction should be affirmed. Respectfully submitted, CYRUS R. VANCE, JR. District Attorney New York County GINA MIGNOLA DEBORAH'. MORSE Assistant District Attorneys Of Counsel August 2011 -63- EFTA00602404 -

- First Department THE PEOPLE OF THE STATE OF NEW YORK, Respondent, - against - JEFFREY E. EPSTEIN Dc.fendant-Appellant. BRIEF FOR RESPONDENT CYRUS R. VANCE, JR. District Attorney New York County Attorney for Respondent One Hogan Place New York, New York 10013 (212) 335-9000 [email protected]

original). However, by phrasing that principle in the permissive way—that the absence of indictment "=" be strong evidence (emphasis supplied)—the Legislature conveyed nothing more than the simple fact that there were circumstances under which the absence of formal charges would, in fact, cast doubt on th

mplaint about either the form or content of that determination. CONCLUSION The judgment of conviction should be affirmed. Respectfully submitted, CYRUS R. VANCE, JR. District Attorney New York County GINA MIGNOLA DEBORAH L. MORSE Assistant District Attorneys Of Counsel August 2011 -63- EFTA00792566

- First Department THE PEOPLE OF THE STATE OF NEW YORK, Respondent, - against - JEFFREY E. EPSTEIN Dcfendant-Appellant. BRIEF FOR RESPONDENT CYRUS R. VANCE, JR. District Attorney New York County Attorney for Respondent One Hogan Place New York, New York 10013 (212) 335-9000 [email protected]

riginal). However, by phrasing that principle in the permissive way—that the absence of indictment "may" be strong evidence (emphasis supplied)—the Legislature conveyed nothing more than the simple fact that there were circumstances under which the absence of formal charges would, in fact, cast doubt on th

mplaint about either the form or content of that determination. CONCLUSION The judgment of conviction should be affirmed. Respectfully submitted, CYRUS R. VANCE, JR. District Attorney New York County GINA MIGNOLA DEBORAH L MORSE Assistant District Attorneys Of Counsel August 2011 -63- EFTA00181213 -

n - First Department THE PEOPLE OF THE STATE OF NEW YORK, Respondent, - against - JEFFREY E. EPSTEIN Defendant-Appellant BRIEF FOR RESPONDENT CYRUS R. VANCE, JR. District Attorney New York County Attorney for Respondent One Hogan Place New York, New York 10013 danyappea s any.nyc.gov GINA MIGNOLA

tion was made, and providod such parson no longor meets the criteria for registration as a sexual offender under the laws of this state. (12) This Legislature finds that lanai offenders, especially those who haws committed offenses &rine. minors, often pt so a high rick of engaging in sexual offenses croon

t APPELLATE DIVISION-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, New York 10013 Attorneys for Respondent JAY P. LEFKOWITZ SANDRA LYNN

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

New York, New York 10013 January 18, 2011 HONORABLE RUTH PICKHOLZ Justice of the Supreme Court APPEARANCES: For the People: For the Defense: CYRUS R. VANCE, JR., ESQ., New York County District Attorney One Hogan Place New York, New York 10013 BY: JENNIFER GAFFNEY, ESQ. Assistant District Attorney K

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

10013 9 January 18, 2011 10 BEFORE: 11 12 HONORABLE RUTH PICKHOLZ Justice of the Supreme Court 13 14 APPEARANCES: 15 16 For the People: CYRUS R. VANCE, JR., ESQ., New York County District Attorney 17 One Hogan Place NewY York 10013 18 BY: GAFFNEY, ESQ. Assis an strict Attorney 19 For th