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People should be estopped from so radically reversing course on appeal. The District Attorney's Office 1 EFTA00792574 was the party representing the State of New York and statutorily bore the burden of proof at the SORA hearing. In direct and reasonable reliance on the People's representations that they would agr
tion, should be vacated, 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
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and presently serving a prison sentence In Palm Beach County, Florida for, inter alia solicitation of prostitution and solicitation of minors to e
ssues Mr. Epstein, through counsel, has fully remedied any perceived breach. Please advise if you for any reason disagree. Respectfully submitted, Jay P. Le owiiz, P.C. Chicago Hong Kong London Los Angeles Munich San Francisco Washington, D.C. EFTA00194706 KIIUCLAND & ELLIS LLP CC: Jeffrey Slo
use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and presently serving a prison sentence in Palm Beach County, Florida for, inter alio solicitation of prostitution and solicitation of minors to e
ssues Mr. Epstein, through counsel, has fully remedied any perceived breach. Please advise if you for any reason disagree. Respectfully submitted, Jay P. Le owifr, Chicago Hong Kong London Los Angeles Munich San Francisco Washington, EFTA00183752 KIRKLAND & ELLIS LLP . N.sq. Esq. EFTA0018375
Entities connected to both the State of New York and Jay P. Le

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
New York
LOCATIONLeon Black
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSONMartin Weinberg
PERSON
Department of Justice
ORGANIZATIONMichael J. Pike
PERSON
Jay Lefkowitz
PERSONFL Bar No.
ORGANIZATION