Epstein Secrets

is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey Epstein presents a negligible risk of reoffending, and indeed, justice demands that his SO

x Crimes Unit ADA Jennifer Gaffney, Deputy Chief, Sex Crimes Unit ADA Patrick Egan, Sex Crimes Bureau and Trial Bureau 40 FROM Jay P. Lefkowitz, Sandra Lynn Musumeci DATE October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30129-2010 Jeffrey Epstein, a 57-

is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey Epstein presents a negligible risk of reoffending, and indeed, justice demands that his SO

ennifer Gaffney, Deputy Chief, Sex Crimes Unit ADA Patrick Egan, Sex Crimes Bureau and Trial Bureau 40 FROM Jay P. Lefkowitz, P.C. Matthew Solum Sandra Lynn Musumeci DATE October 5, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30129-2010 New York's Sex Offende

is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey- Mr. Epstein presents a negligible risk of reoffending, and indeed, justice demands that h

mes Unit ADA Jennifer Gaffney, Deputy Chief, Sex Crimes Unit ADA Patrick Egan, Sex Crimes Bureau and Trial Bureau 40 FROM Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci DATE October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30129-2010 Jeffrey Epstein is ;4

der SORA was unsupportable under the legally mandated "clear and convincing evidence" standard. See Correction Law §§ 168.1(2), 168- n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008). B. The District Attorney's Office Appropriately Applied the Governing Legal Standard, As Set Forth by SORA and Its Gu

ted, and Appellant's SORA level should be recalculated in accordance with the law. September 16, 2011 Respectfully submitted, Jay P. Le owitz. P Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 Counsel for Defendant-Ap

ar and convincing evidence" standard, as the People rightfully represented at the SORA hearing. See Correction Law §§ 168-k(2), 168-n(2); People v. Johnson, 11 N.Y.3d 416, 421 (2008). 12 EFTA00798132 A. The People Rejected the Board Recommendation As Unreliable Following Several Months of Investig

level should be recalculated in accordance with the law. September 16, 2011 Respectfully submitted, /s/ Jay P. Lefkowitz Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRICLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein 4

der SORA was unsupportable under the legally mandated "clear and convincing evidence" standard. See Correction Law §§ 168- k(2), 168-n(2); People v. Johnson, 11 3d 416, 421 (2008). B. The District Attorney's Office Appropriately Applied the Governing Legal Standard, As Set Forth by SORA and Its Guide

nterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. /s/ Jay P. Lefkowitz Jay P. Lefkowitz, Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 32 EFTA00584132

e v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y. S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196 (4th Dep't 2006) 39 People v. Judson, 50 A.D.3d 1242 (3d Dep't 2008) 27 People u.

g evidence, to wit, the undisputed conduct encompassed by Appellant's registerable crime of conviction. February 22, 2011 Respectfully submitted, Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein E