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

w York -- has determined that it will not require Mr. Epstein to register at all under that state's sexual offender reporting statute. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit C); see also NMSA 1978, § 29-11A-3(E). As previously noted,

igned To Impose Reporting Requirements Upon Offenders In Proportion To The Threat They Pose To The Public So That They May Be Adequately Monitored New York's Sex Offender Registration Act (SORA), Correction Law § 168 et aL is intended to impose the most stringent reporting requirements on those sex offend

registration requirements here in New York -- if indeed it qualifies as registerable at all. At most, Mr. Epstein was guilty of a misdemeanor under New York law, and accordingly, his registration obligations under SORA should reflect this relative lack of severity of his offense. Even under the broader

under that state's sexual offender reporting statute, despite his Florida conviction and the conduct alleged in connection therewith. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit E); see also NMSA 1978, § 29-11A-3(E). Notwithstanding the

d the reasoned determinations of other jurisdictions having greater contact and control over Mr. Epstein, the Board of Examiners of Sex Offenders in New York has recommended that Mr. Epstein be categorized as a Level 3 sex offender. Such a harsh designation would subject Jeffrey Epstein to a lifetime obli

oted that the New York cognate of this crime, Promoting Prostitution in the Third Degree, P.L. § 230.25, is not itself a registerable offense under New York's New York's Sex Offender Registration Act (SORA), Correction Law § 168-a(2). Moreover, the conduct underlying this conviction -- a consensual arrange

w York -- has determined that it will not require Mr. Epstein to register at all under that state's sexual offender reporting statute. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit C); see also NMSA 1978, § 29-11A-3(E). As previously noted,

n the Information, he received massages and engaged in sexual touching in exchange for money with A.D., a young woman over the age of consent under New York law for all but two months of the fourteen month period during which this conduct is alleged to have occurred Asut--just-under--1-8-fer--all-but-two

ng Requirements Upon Offenders In Proportion To The Threat They Pose To The Public So That They May Be Adequately Monitored As you are well aware, New York's Sex Offender Registration Act (SORA), Correction Law § 168 et at is intended to impose the most stringent reporting requirements on those sex offen

nder that Sstate's sexual offender reporting statute, despite his Florida conviction and the conduct alleged in connection therewith. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit E); see also NMSA 1978, § 29-11A-3(E). Notwithstanding the

court. 18 U.S.C.A. § 3142. EFTA00066193 U.S. v. EPSTEIN Cite u423 F.Supp.34 306 (S.D.N.Y. 2019) Pro Hac Vice, United States Attorney's Office, New York, NY, Gloria Rachel Allred, Allred, Maroko & Goldberg, Los Angeles, CA, for Government. James L. Brochin, Michael Campion Miller, Michael Gerard S

in Islands With respect to Mr. Epstein's sex of- fender status in New Mexico, Defense Counsel has submitted a letter, dated Au- gust 19, 2010, from Regina Chacon, Assis- tant Bureau Chief, Law Enforcement Record Bureau of the New Mexico De- partment of Public Safety, which states that Mr. Epstein "is not req

court. 18 U.S.C.A. § 3142. EFTA00076817 U.S. v. EPSTEIN Cite u423 F.Supp.34 306 (S.D.N.Y. 2019) Pro Hac Vice, United States Attorney's Office, New York, NY, Gloria Rachel Allred, Allred, Maroko & Goldberg, Los Angeles, CA, for Government. James L. Brochin, Michael Campion Miller, Michael Gerard S

in Islands With respect to Mr. Epstein's sex of- fender status in New Mexico, Defense Counsel has submitted a letter, dated Au- gust 19, 2010, from Regina Chacon, Assis- tant Bureau Chief, Law Enforcement Record Bureau of the New Mexico De- partment of Public Safety, which states that Mr. Epstein "is not req