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ct Attorney, Sex Crimes Unit / Trial Bureau 40 New York District Attorney's Office One Hogan Place New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #30129-2010 Dear ADA Gaffney and ADA Egan: As you know, we represent Jeffrey E. Epstein, who is scheduled to a
ieve expose the stark contrast between the inflammatory, speculative case summary presented by the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning the alleged conduct for which New York seeks to require Mr. Epstein to register under SORA. We hope
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #30
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #301
the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning
th Epstein was consensual. EFTA00723420 KIRKLAND & ELLIS LLP Jennifer Gaffney, Esq. and Patrick Egan, Esq. October 26, 2010 Page 3 • See also Recarey Dep. 418:14419:5 (Recarey testifying that M. told him in November 2005 that she had consensual sex with Epstein shortly before their interview, when M.
ct Attorney, Sex Crimes Unit / Trial Bureau 40 New York District Attorney's Office One Hogan Place New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #30129-2010 Dear ADA Gaffney and ADA Egan: As you know, we represent Jeffrey E. Epstein, who is scheduled to a
keep track of specifically when different events with Epstein took place). While= could not say with certainty when she first met and massaged Mr. Epstein= stated definitively and unambiguously that she was 17 years old during their single instance of brief sexual intercourse, when she claimed that Mr.
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #30
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case #301
the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning
was consensual. EFTA00723430 KIRKLAND & ELLIS LLP Jennifer Gaffney, Esq. and Patrick Egan, Esq. October 27, 2010 Page 3 • See also Exhibit B, Recarey Dep. 418:14-419:5 (Recarey testifying that M. told him in November 2005 that she had consensual sex with Epstein shortly before their interview, when M
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
d prosecutor specializing in sex crimes cases involving children, concluded following her investigation that, "There are no real victims here." See Recarey Dep. 484:21-485:13, 506:18-507:21. In short, there is a wealth of evidence, gathered and considered by the Florida prosecutors who closely examined and
Entities connected to both Jeffrey Epstein and Recarey Dep

New York
LOCATION
Jay Lefkowitz
PERSONKirkland & Ellis LLP
ORGANIZATION
Munich
LOCATION
Shanghai
LOCATIONJoe Recarey
PERSON
Palo Alto
LOCATIONMySpace
ORGANIZATION
Ruth Pickholz
PERSON
Jennifer Gaffney
PERSONSandra Lynn Musumeci
PERSONSex Crimes Unit
ORGANIZATIONNew York District
LOCATIONPatrick M. Regan
PERSONFelony Solicitation for Prostitution
ORGANIZATIONADA Egan
ORGANIZATIONSex Crimes Unit / Trial Bureau
ORGANIZATIONPersonal Income Tax Audit Changes
ORGANIZATIONthe New York State Department of Taxation
ORGANIZATIONthe Recarey Probable Cause Affidavit
ORGANIZATION