Epstein Secrets

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

order to improperly and incorrectly build a case that Appellant had a propensity for underage girls. Indeed, the Probable Cause Affidavit and the People's appellate brief both underscore the extremely damaging claim that Appellant allegedly relayed to H.R. that his preference for female masseuses was,

program (McAfee Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. Jay PJLefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: EFTA00231598 SUPREME COURT FOR THE STATE OF NEW YORK

nd review a written statement of the People's recommended determination and order where defendant and court did not receive proper 10-day notice of People's revised RAI); cf. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was

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

nd review a written statement of the People's recommended determination and order where defendant and court did not receive proper 10-day notice of People's revised RAI); ef. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was