Epstein Secrets

-erifieitl-distirtetion-between-the-Fleridit-seature-te whieh-Mfr E-peteiri-pleeelerl-guitty-arki-the-Neve-Yerk-eegaater it-is-riet-even-elear-that-Mfr Epstein committed an offense which is registerable under Ncw York law. While the Florida law critninalistes-parronithig-a-prostitute-who-is-uridethe-itge-el

spite his Florida conviction and the conduct alleged in connection therewith. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit E); see also NMSA 1978, § 29-11A-3(E). Notwithstanding the Sstate's determination that he need not register, Mr. Epstein v

onviction for a prostitution-related offense, committed in Florida (wherehe-alse-ewris-a-vaeatien-heine)-dating back to 2005. On June 30, 2008, Mr. Epstein pleaded guilty in the Circuit Court for Palm Beach County, Florida under an Information to the charge of Procuring a Person Under 18 for Prostituti

indeed, by the terms of the SORA statute itself, should not be required to register. See Correction Law § 168-a(2)(a)(i).7 Indeed, nothing about Mr. Jeffrey-Epstein's interactions with A.D. -- other than A.D.'s age, which she concealed from him and has not been established to be under the age of consent under New

October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 3

October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30

en-heine)-dating back to 2005. On June 30, 2008, Mr. Epstein pleaded guilty in the Circuit Court for Palm Beac

ld needlessly duplicate -- and indeed, unnecessarily go well beyond -- the efforts of jurisdictions having much greater contact with and control over Jeffrer . Mr. Epstein. In addition, designating Jeffrey Mr. Epstein as a Level 3 offender would require him to return to New York to re-register every 90

rd of Examiners of Sex Offenders with the knowledge that they will be relied on by courts generally constitute "reliable hearsay" in SORA hearings, the New York Court of Appeals has held that a Board case summary "may be rejected when it is unduly speculative or its accuracy is undermined by other more compelling evidence."

ureau 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 Offender Registration Act (SORA), Correction Law § 168 et aL is intended to impose

lorida but owns a vacation home in Manhattan, and who has never before been convicted of a crime, clearly belongs in this latter category. Given Mr. Epstein's history and personal characteristics, the circumstances of the offense which triggered the registration requirement, his acceptance of responsibi

echoed in the words of the clinical psychologist who has worked with Mr. Epstein following his arrest/conviction for the instant offense [when did JE begin with therapy?]. That doctor, Stephen R. Alexander, Psy.D., has praised Mr. Epstein's cooperativeness, self-reflection, and receptiveness to t

October 5, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 3

October 5, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30

e, clearly belongs in this latter category. Given Mr. Epstein's history and personal characteristics, the circ

rd of Examiners of Sex Offenders with the knowledge that they will be relied on by courts generally constitute "reliable hearsay" in SORA hearings, the New York Court of Appeals has held that a Board case summary "may be rejected when it is unduly speculative or its accuracy is undermined by other more compelling evidence."

spite his Florida conviction and the conduct alleged in connection therewith. See Letter of Regina Chacon, New Mexico Department of Public Safety to Jeffery E. Epstein, August 19, 2010 (Exhibit E); see also NMSA 1978, § 29-11A-3(E). Notwithstanding the state's determination that he need not register, Mr. Epstein vo

conviction for a prostitution-related offense committed in Florida (where he also owns a vacation home) dating back to 2005. On June 30, 2008, Mr. Epstein pleaded guilty in the Circuit Court for Palm Beach County, Florida under an Information to the charge of Procuring a Person Under 18 for Prostituti

October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 3

October 7, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30

ion home) dating back to 2005. On June 30, 2008, Mr. Epstein pleaded guilty in the Circuit Court for Palm Beac

rd of Examiners of Sex Offenders with the knowledge that they will be relied on by courts generally constitute "reliable hearsay" in SORA hearings, the New York Court of Appeals has held that a Board case summary "may be rejected when it is unduly speculative or its accuracy is undermined by other more compelling evidence."

566 78, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009), lieges that she was "forced to engage in sexual acts with Dershowitz in, among other locations, [Jeffrey] Epstein's mansion ...." (Complaint ("Compl."), dated Apr. 16, 2019 [dkt. no. 1], at ¶ 36). Prior to filing the Complaint, she had filed a joinder motion in

what she believed happened" but Dershowitz asserted that Ms. had "made an honest mistake and had confused [Dershowitz] with another friend of Mr. Epstein." (Id.) Boies says that Dershowitz "was never able to substantiate his assertions" and that the Firm was "increasingly uncovering evidence that wa

acts with Dershowitz in, among other locations, [Jeffrey] Epstein's mansion ...." (Complaint ("Compl."),

had confused [Dershowitz] with another friend of Mr. Epstein." (Id.) Boies says that Dershowitz "was never ab

enteen years earlier. The defendant sold and delivered a copy of the newspaper to the plaintiff's agent seventeen years after publication, and, as the New York Court of Appeals summarized it, the English court held "each delivery to a third person of a defamatory article constituted a new publication of the libel, which i

ttorneys for Respondent Sharon Churcher BY: ERIC J. FEDER LAW OFFICES OF Attorneys BY: GREGORY L. RACHEL S. GREGORY L. POE PLLC for Respondent Jeffrey Epstein POE LI WAI SUEN SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024108 EFTA01737512 2 G6ndgium 4 5 6 7 8 9 10 11 12 13

on. We need to see what they're specifically talking about here. THE COURT: Thank you very much. I will reserve decision. The motion to quash the Epstein -- MR. POE: May I approach the podium, your Honor? THE COURT: Yes. Of course. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024133

N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAI

s whether in fact an undue burden would exist if Mr. Epstein were subjected at this point to a deposition. Th

urdened with going and sitting for a deposition where her counsel basically objects to every question as privileged under the Shield Law. And both the New York Court of Appeals and the Second Circuit have emphasized that. The New York Court of Appeals said, in Holmes v. Winter, which we cite in our brief, where the entire

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Fwd: Alert: Cay

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Fwd: Alert:

hat the acts of a corporation's agents are imputed to the corporation - regardless of whether the agents are insiders. The Lehr court observed that the New York Court of Appeals made clear in Kirschner that the doctrine of in pari delicto had only one "narrow" exception to imputation - the adverse interest exception. The Le