Epstein Secrets

To be Argued By: JAY P. LEFKOWITZ New York County Clerk's Index No. 30129/2010 .ettr 'lark $upreme Court APPELLATE DIVISION-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN,

pellant did not have a meaningful opportunity to present evidence on his own behalf because 1 As set forth in greater detail in Section II, infra, the District Attorney's Office was presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and discussion

ief in response. I look forward to hearing your opinion. Yours truly, (44.e /-C__) Deborah L. Morse Assistant District Attorney EFTA00181233 New York County Clerk's Index No. 30129/2010 Nye 1' Ink *inane (&mrt APPELLATE DIVISION-FIRST DEPARTMENT I, 14 I PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. E

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre

in response. I look forward to hearing your opinion. Yours truly, ti 6t 1 of Lc.) Deborah L. Morse Assistant District Attorney EFTA00231442 New York County Clerk's Index No. 30129/2010 'sin 'Dark $ig:matte &curt APPELLATE DIVISION-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, Respondent, —against— JEFFR

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre

peal, as well as a copy of our brief in response. I look forward to hearing your opinion. Yours truly, Deborah L. Morse Attorney EFTA00232562 New York County Clerk's Index No. 30129/2010 'et' Vark tyrant arrurt APPELLATE DIVISION—FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN,

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre