Epstein Secrets

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. 7, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorney assigned to the SORA

ssumed by him, at least where he had, or was chargeable with, full knowledge of the facts and another will be prejudiced by his action."); see also Kilcer v. Niagara Mohawk Power Corp., 86 A.D.3d 682, 682 (3d Dep't 2011) (observing "the litigant should be bound by the prior stance that he or she clear

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

's improper Level 3 SORA adjudication stands in stark contrast to the People's position at the SORA hearing itself and should not be permitted. See Kilcer v. Niagara Mohawk Power Corp., 86 A.D.3d 682, 682 (3d Dep't 2011) ("A litigant should not be permitted to lead a tribunal to find a fact one way an

ounsel 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 SORA

3 4 EFTA00584104 SORA adjudication stands in stark contrast to the People's position at the SORA hearing itself and should not be permitted. See Kilcer v. Niagara Mohawk Power Corp., 86 3d 682, 682 (3d Dep't 2011) ("A litigant should not be permitted to lead a tribunal to find a fact one way and