Epstein Secrets

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-

t. 2010) (observing "the risk level designated in the RAI 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 r

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

t. 2010) (observing "the risk level designated in the RAI 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 r

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

t. 2010) (observing "the risk level designated in the RAI 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

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

" and that hearsay evidence "may be attacked in any of the usual ways"). The People acknowledge as much in their citation and repeated reference to People v. Mingo, 12 N.Y.3d 563, 577 (2009) (noting the unreliability of a victim's statement where it is "equivocal, inconsistent with other evidence, or seems dub

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

y proven false, and directly contradicted by non-hearsay evidence. CITE. The People acknowledge as much in their citation and repeated reference to People v. Mingo, 12 N.Y.3d 563, 577 (2009) (noting the unreliability of a victim statement where it is "equivocal, inconsistent with other evidence, or seems dubio

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

" and that hearsay evidence "may be attacked in any of the usual ways"). The People acknowledge as much in their citation and repeated reference to People v. Mingo, 12 IMI.3d 563, 577 (2009) (noting the unreliability of a victim statement where it is "equivocal, inconsistent with other evidence, or seems dubio