Epstein Secrets

s 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 respectfully submit this letter and the accompanying materials for your cons

of all, because the offense which triggered the registration requirement in Florida — and then, solely by virtue of Correction Law § 168-a(d)(2), in New York — would not have been a registerable offense at all (and almost certainly would have only been a misdemeanor) had it been committed in New York inst

(212) 446-4800 October 11, 2010 Facsimile: (212) 446-4900 By E-mail CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chief, Sex Crimes Unit New York District Attorney's Office One Hogan Place New York, NY 10013 Patrick Egan, Esq. Assistant District Attorney, Sex Crimes Unit / Trial Bureau 40 New York

s 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 October 13, and as you have

ted point, we note that upon further consideration and investigation, our current view is that Jeffrey Epstein should not be required to register in New York at all.5 Mr. Epstein maintains his primary residence in the U.S. Virgin Islands and does not actually live, work, or attend school in New York, the

(212) 446-4800 Facsimile: (212)446-4970 October 26, 2010 By E-mail CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chief, Sex Crimes Unit New York District Attorney's Office One Hogan Place New York, NY 10013 Patrick Egan, Esq. Assistant District Attorney, Sex Crimes Unit / Trial Bureau 40 New York

s 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 October 13, and as you have

ted point, we note that upon further consideration and investigation, our current view is that Jeffrey Epstein should not be required to register in New York at all.5 Mr. Epstein maintains his primary residence in the U.S. Virgin Islands and does not actually live, work, or attend school in New York, the

Facsimile: winv.kIrkland.com October 27, 2010 By E-mail and By Hand CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chief, Sex Crimes Unit New York District Attorney's Office One Hogan Place New York, NY 10013 Patrick Egan, Esq. Assistant District Attorney, Sex Crimes Unit / Trial Bureau 40 New York

s 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 feu our conversation in your office on October 13, and as you have

ted point, we note that upon further consideration and investigation, our current view is that Jeffrey Epstein should not be required to register in New York at all.5 Mr. Epstein maintains his primary residence in the U.S. Virgin Islands and does not actually live, work, or attend school in New York, the

212) 4464970 www.kindand.com October 26-,a 2010 By E-mail and By Hand CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chief, Sex Crimes Unit New York District Attorney's Office One Hogan Place New York, NY 10013 Patrick Egan, Esq. Assistant District Attorney, Sex Crimes Unit / Trial Bureau 40 New York

and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Und

ed pertained to consensual, commercial, non-violent interaction with one woman, A.D., who was 17 years old (and therefore over the age of consent in New York but not in Florida) at the time of the relevant conduct. See A.31 (Information for Procuring Person Under 18 for Prostitution, dated June 26, 2008);

orney The SORA hearing, originally scheduled for September 15, 2010, was adjourned on consent of the parties until January 18, 2011 to provide the New York District Attorney ("the People"), which represented the State of New York at the SORA hearing, an opportunity to investigate Appellant's Florida convictions

and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Und

ed pertained to consensual, commercial, non-violent interaction with one woman, A.D., who was 17 years old (and therefore over the age of consent in New York but not in Florida) at the time of the relevant conduct. See A.31 (Information for Procuring Person Under 18 for Prostitution, dated June 26, 2008);

orney The SORA hearing, originally scheduled for September 15, 2010, was adjourned on consent of the parties until January 18, 2011 to provide the New York District Attorney ("the People"), which represented the State of New York at the SORA hearing, an opportunity to investigate Appellant's Florida convictions

age of 17, and the wholly consensual conduct in exchange for money which occurred between the two would not even have been a registerable offense in New York. See §168-a(2XaX0(§230 .04 a registerable offense only if "person patronized" is in fact under 17 years old). Indeed, at the time of the offense at

and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Und

orney The SORA hearing, originally scheduled for September 15, 2010, was adjourned on consent of the parties until January 18, 2011 to provide the New York District Attorney ("the People"), which represented the State of New York at the SORA hearing, an opportunity to investigate Appellant's Florida convictions

age of 17, and the wholly consensual conduct in exchange for money which occurred between the two would not even have been a registerable offense in New York. See §168-a(2XaXi)(§230.04 a registerable offense only if "person patronized" is in fact under 17 years old). Indeed, at the time of the offense at

and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Und

orney The SORA hearing, originally scheduled for September 15, 2010, was adjourned on consent of the parties until January 18, 2011 to provide the New York District Attorney ("the People"), which represented the State of New York at the SORA hearing, an opportunity to investigate Appellant's Florida convictions

SORA designation: communicate with legal team re DA's decision to consent to a level 1 SORA adjudication. 12/28/10 .75 Sandra L Musumeci Review New York's Sexual Offender Registration Act re obligation for registrant to appear in court: speak with D. Indyke re status of case. 12/29/10 2.25 Sandra L

er under SORA. Research Article 78 options per J. Epstein and D. Indyke: look into SORA issues re challenge to statute. Speak with J. Gaffney of New York District Attorney's Office to get update on their position on SORA issue: speak with J. Lefkowitz re future strategy re SORA issue: draft e-mail to team s

o is scheduled to appear in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing befo a Honorable Ruth Pickholz pursuant to New York's Sex Offender Registration Act (SORA), . Correction Law § 168 et seq. (McKinney 2008). To follow up on our conversation in your office on October

. To Call Writer Dire October October 28, 2010 By E-mail and By Hand CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chief, Sex Crimes Unit New York District Atto Patrick Egan, Esq. Assistant District Attorney, Sex Crimes Unit / Thal Bureau 40 New York District Attorney's Office Re: SORA Determination