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

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

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

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

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

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

iv EFTA00792573 INTRODUCTION In a stunning reversal of the position they espoused on the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designati

YWELL Notary Public State of New York No Qualified in Kings County Commission Expires November 15. 2012 /s/ Howard Daniels Case Name: People v. Epstein EFTA00792607

MENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. REP

MENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. REPL

" 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

INTRODUCTION In a stunning reversal of the position they espoused on the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designati

A hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the order of the New York Supreme Co

at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the order of the New York S

at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the order of the New York Su

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

INTRODUCTION In a stunning reversal of the position they espoused on the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designati

A hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Co

at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York S

at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Su

" 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