Epstein Secrets

ict Attorney, Sex Crimes Unit / Trial Bureau 40 New York District Attorneys Office One Hogan Place New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30129-2010 Dear ADA Gaffney and ADA Egan: As you know, we represent Jeffrey E. Epstein, who is scheduled to

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 beli

New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 3

New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30

the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning

rd). All of this conduct involving II. would have constituted, at most, a non-registerable misdemeanor if committed in New York instead of Florida. See N.Y. Penal Law § 230.04 (McKinney 2004).4 Because it cannot be proven by "clear and convincing evidence (or indeed, by any credible evidence) that Mr. E

3)(United States District Court, S.D. Fl.); v. Jeffrey Epstein (Case No. 502008CA028051XXXXMB AB)(Florida Circuit Court, 15th Judicial Circuit). v. Jeffrey Epstein (Case No. 502008CA028058XXXXMB ABXFlorida Circuit Court, 15th Judicial Circuit). 3. In December 2009, Epstein brought a vendetta action against me

itution in Florida. Subsequently, Bradley James Edwards, a Florida lawyer, brought civil actions on behalf of several girls alleging molestation by Epstein while they were minors. Jane Doe v. Jeffrey Epstein, (08- 80893)(United States District Court, S.D. Fl.); E v. Jeffrey Epstein (Case No. 502008CA

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(a)11 taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

n between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the C

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

ail to two other persons — attorney Brad Edwards and private investigator Michael Fisten. Accordingly, any privilege has now been obviously waived. See N.Y. Civil Rights Law CRL § 79-h(g) (reporter privilege waived through voluntary disclosure of information). 11. Second, even if the material could some

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

ted. New York law does not itself deem the underlying conduct of Appellant's registerable Florida conviction to be registerable under New York law. See N.Y. Penal Law § 230.25; Correction Law § 168-a(2). In other words, Appellant's conviction, if secured under New York law rather than Florida law, would