Epstein Secrets

ellarges-te-whia-Jefftest-Eptiteitt-pleatle4 ,uilty in Florida, it must be noted that sole offense for which Mr. Epstein is required to register in-New-York-untler-SORA a June-30;-2008-plea-in-the-Gireuit Court-fofrPalm Butch Courtly; Florida under an Information to the charge of Procuring a Person Under

-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-eleighteen-fiTerki-antl-1-7-years-e14 ihe-equivalent-New-Yer

evel I Under SORA Will More Than Adequately Protect The People Of New York From Any Negligible Threat Posed By Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that the intentions of SORA will be fully realized by imposing on Mr. Jeffrey-Epstein a Level 1 designation for his Flor

NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New Ynrk 10022-4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORN

gan Place New York, NY Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of th

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre

10013 Telephone: (212) 335-9000 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of th

on of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00589579 discretion and constituted reversible legal error, as the District Attorney's Office agreed that there was not clear and convincing evidence to support a Level 3 designation. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PE

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 designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

pellant did not have a meaningful opportunity to present evidence on his own behalf because 1 As set forth in greater detail in Section II, infra, the District Attorney's Office was presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and discussion

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 designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

osition of the Assistant District Attorney charged with representing the State and instead, 1 As set forth in greater detail in Section II, infra, the District Attorney's Office was already presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and di

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 designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

hts to which he is entitled and which deprivation of those rights their actions occasioned. 2 As set forth in greater detail in Section II, infra, the District Attorney's Office was already presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and di

-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, Respondent, —against— JEFFREY E. EPsTEIN, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New Yor New York 10013 Attorneys for Respondent JAY P. LEFKOWITZ SANDRA LYNN MUSUMECI KIR1CLAND & E

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre

—FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. APPENDIX CYRUS R. VANCE, JR. NEW YORK COUNTY DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, New York 10013 Attorneys for Respondent JAY P. LEFICOWTIZ SANDRA LYNN MUSUMECI KIRK AND &

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre