Epstein Secrets

n. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND ELLI LLP 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE On

on of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00589579 discretion and constituted reversible legal error, as the District Attorney's Office agreed that there was not clear and convincing evidence to support a Level 3 designation. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PE

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-

evel I Under SORA Will More Than Adequately Protect The People Of New York From Any Negligible Threat Posed By Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that the intentions of SORA will be fully realized by imposing on Jeffrey Epstein a Level 1 designation for his Florida

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

ORA Will More Than Adequately Protect the People of the State of New York from Any Negligible Threat Posed by Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that intentions of SORA will be fully realized by imposing on Jeffrey Epstein a Level 1 designation for his Florida conv

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

evel I Under SORA Will More Than Adequately Protect The People Of New York From Any Negligible Threat Posed By Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that the intentions of SORA will be fully realized by imposing on Mr. Jeffrey-Epstein a Level 1 designation for his Flor

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

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

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

osition of the Assistant District Attorney charged with representing the State and instead, 1 As set forth in greater detail in Section II, infra, the District Attorney's Office was already presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and di

n. There has been no change in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New Ynrk 10022-4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL

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

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

hts to which he is entitled and which deprivation of those rights their actions occasioned. 2 As set forth in greater detail in Section II, infra, the District Attorney's Office was already presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and di