Epstein Secrets

E OF NEW • YORK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP

ts and designated Epstein as a level three sex offender. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. At a hearing preceding her ruling, Justice Pickholz told the Assistant District Attorney that she had "never seen the 3 4811-3721-9459v.2 3930°33-000039 EFTA00805354 prosecutor's office do anythin

because "there are no real victims here." Id. Ex. C. In January 2011, the judge presiding over the sex-offender registration proceedings, Justice Ruth Pickholz, rejected ADA Gaffney's arguments and designated Epstein as a level three sex offender. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. At a hearing

OF NEW YORK APPELLATE DIVISION - FIRST DEPARTMENT x THE PEOPLE OF THE STATE OF NEW • YORK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT O

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00792402 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

upreme Court Part 66 III Centre Street New York, NY 10013 FacsrmM www.lOrklang com September 7, 2010 / Re: SCID No. 30129-2010 Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30 a.m. on Wednesday

'S OFFICE One Hogan Place New York, NY 10013 Telephone: (212) 335-9000 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) heari

lm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008 A47 EFTA00181235 UI PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

The Honorable Ruth Pickholz New York County Supreme Court Part 66 It 1 Centre Street New York, NY 10013 Re: SCID No. 30129-2010 Dear Justice Pickholz: I ant writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30>a.m. on Wednesda

YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) heari

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00180924 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

The Honorable Ruth Pickholz New York County Supreme Court Part 66 Ill Centre Street New York, NY 10013 Re: SCID No. 30129-2010' Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:304.m. on Wednesday,

DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYili m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) heari

earing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, according to a transcript of the hearing. Ms. Gaffney agreed that it was "incredibly unusual for us to make a downward argument,"

most [district attorneys] want an upward departure, never down," Mr. Weber said. Ms. Gaffney had to defend her decision at a January 2011 hearing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, accor

earing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, according to a transcript of the hearing. Ms. Gaffney agreed that it was "incredibly unusual for us to make a downward argument,"

most [district attorneys] want an upward departure, never down," Mr. Weber said. Ms. Gaffney had to defend her decision at a January 2011 hearing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, accor

Case #30129-2010 Dear ADA Gaffney and ADA Egan: As you are aware, we represent Jeffrey E. Epstein, who is scheduled to appear before the Honorable Ruth Pickholz in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing pursuant to New York's Sex Offender Registration Act (SORA), Correcti

Dear ADA Gaffney and ADA Egan: As you are aware, we represent Jeffrey E. Epstein, who is scheduled to appear before the Honorable Ruth Pickholz in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing pursuant to New York's Sex Offender Registration Act (SORA), Correction Law § 168 et seq.. We

ns. Perform all levels of case management: review case files for key correspondence: append pleading files. Draft and revise letter to Judge R. Pickholz re January 18. 2011 SORA hearing: communicate with legal team re draft letter and potential follow-up actions. Review case files for extra copies

ci 6.75 1/24/11 Michelle T Denny 2.00 Page 6 Description action. Read S. Musumeci e-mail re next steps. Review and copy official file from New York Supreme Court: draft e-mail update and analysis to legal team: conduct legal research re procedural requirements for filing appeal and motion for a stay: cond

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00231445 in PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYiiii m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJEGF-OF-ThE-C-AUSE-OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hear

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00232565 in PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYail m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. -6.—THE NATURE AND OBJECT OFIIIE CAUSE-OF-ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hear