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rey E. Epstein, who is scheduled to appear in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing before the Honorable Ruth Pickholz pursuant to New York's Sex Offender Registration Act (SORA), Correction Law § 168 et seq.. To follow up on our conversation in your office on Octob
was consensual. EFTA00723430 KIRKLAND & ELLIS LLP Jennifer Gaffney, Esq. and Patrick Egan, Esq. October 27, 2010 Page 3 • See also Exhibit B, Recarey Dep. 418:14-419:5 (Recarey testifying that M. told him in November 2005 that she had consensual sex with Epstein shortly before their interview, when M
rey E. Epstein, who is scheduled to appear in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing before the Honorable Ruth Pickholz pursuant to New York's Sex Offender Registration Act (SORA), Correction Law § 168 et seq.. To follow up to our conversation in your office on Octob
th Epstein was consensual. EFTA00723420 KIRKLAND & ELLIS LLP Jennifer Gaffney, Esq. and Patrick Egan, Esq. October 26, 2010 Page 3 • See also Recarey Dep. 418:14419:5 (Recarey testifying that M. told him in November 2005 that she had consensual sex with Epstein shortly before their interview, when M.
counsel and sought a brief adjournment to provide counsel an opportunity to prepare for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorney assigned to the SOR
d prosecutor specializing in sex crimes cases involving children, concluded following her investigation that, "There are no real victims here." See Recarey Dep. 484:21-485:13, 506:18-507:21. In short, there is a wealth of evidence, gathered and considered by the Florida prosecutors who closely examined and
Entities connected to both Ruth Pickholz and Recarey Dep

Jeffrey Epstein
PERSON
New York
LOCATION
Jay Lefkowitz
PERSONKirkland & Ellis LLP
ORGANIZATIONJoe Recarey
PERSON
Shanghai
LOCATION
Jennifer Gaffney
PERSON
Palo Alto
LOCATIONFelony Solicitation for Prostitution
ORGANIZATIONSex Crimes Unit
ORGANIZATION
Munich
LOCATIONSandra Lynn Musumeci
PERSONNew York District
LOCATIONPatrick M. Regan
PERSONMySpace
ORGANIZATIONADA Egan
ORGANIZATIONSex Crimes Unit / Trial Bureau
ORGANIZATIONPersonal Income Tax Audit Changes
ORGANIZATIONthe New York State Department of Taxation
ORGANIZATIONthe Recarey Probable Cause Affidavit
ORGANIZATION