Epstein Secrets

his own sexual perversions. Ile scores as a Level III Sex Offender with absolu►ely no basis for downward depanure. EFTA00232642 A77 Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 09/07/2010 09:55 FAX 0 2:00 2 KIRKLAND & ELLIS LLP NIO ar

hearing on this matter if that would be acceptable to the Court. We are available to discuss at the Court's convenience. Respe» fully submitted, . Lefkowitz, P.C. Chicago Hong Kong London Los Angeles Munich Palo Alto San Francisco Shanghai Washington. O. C. EFTA00232643 A78 Letter from Suprem

e calendar, matter of Jeffrey Epstein. Your appearances please. MS. GAFFNEY: Gaffney for the People. Good afternoon, Your Honor. MR. LEFKOWITZ: Jay Lefkowdtz and Sandra Musumeci for Mr. Epstein. THE COURT: Mr. Epstein is not here. MR. LEFKOWITZ: That's correct. THE COURT: Are you waiving his appearance

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

-FIRST DEPARTMENT PEOPLE OF THE STATE OF NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. BRIEF FOR DEFENDANT-APPELLANT JAY P. LE•FKOWITZ SANDRA LYNN MUSUMECI KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLE

To be Argued By: JAY P. LEFKOWITZ New York County Clerk's Index No. 30129/2010 e€

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

urt to Counsel Informing of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00792402 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Uni

W PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Ja . Lefkowitz, P.C. S dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212)

tion was made, and providod such parson no longor meets the criteria for registration as a sexual offender under the laws of this state. (12) This Legislature finds that lanai offenders, especially those who haws committed offenses &rine. minors, often pt so a high rick of engaging in sexual offenses croon

ve of the $526,466 already paid by Mr. Epstein - meet the criteria set forth by the NPA. We assure you that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the NPA language, and Mr. Critton, each strongly believe that significant amounts of the fees and costs

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

from passing another type of retroactive legislation, laws "impairing the Obligation of Contracts." The Fifth Amendments Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of "just compensa

for itself." That the provisions of ¶8 are "far from simple" is illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel, Jay Lefkovvitz, who repeatedly advised Mr. Acosta, by letter, that he considered the waiver of liability to be limited to those who agreed to damages, and was ina

that both Mr. Epstein's prior civil counsel, Jay Lefkowitz, who, with you, was a primary negotiator of the N

rom passing another type of retroactive legislation, laws "impairing the Obligation of Contracts," The Fifth Amendment's Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of "just compensa

urt to Counsel Informing of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00180924 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Uni

OW PENDING IN ANY COURT OF THIS OR ANY OTHER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: February 9, 2011 Jar. Lefkowitz, P.C. S dra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: Facsimile: Attorneys for Defendan

nation was made, and provided such penem no longer moots the criteria for registration as a sexual offender untie the laws of this state. (12) lho Legislature finds that sexual offonders, especially those who bevel committed offenses against minors, often pose a high risk of origaginc In sexual offenses ae

is own sexual perversions. l le scores as a Level ill Sex Offender with absolutely no basis for downward departure. EFTA00231522 A77 Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing. dated September 9, 2010 09/0T/2010 09:55 FAX rihon2,,no2 KIRKLAND & ELLIS LLP ANO

a hearing on this matter if that would be acceptable to the Court. We are available to discuss at the Court's convenience. Respectfully submitted, Lefkowitz, P.C. Chicago Hong Kong Lor1000 Los Angeles Memel Palo Alto San Francisco Shanghai Washington. 0 C. EFTA00231523 A78 Letter from Supreme

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

Granting Motion for Limited Appearance of Jay P. Lefkowitz) (Critton, Robert) (Entered: 05/21/2009) 05/21/

rom passing another type of retroactive legislation, laws "impairing the Obligation of Contracts! The Fifth Amendment's Takings Clause prevents the Legislature (and other government actors) from depriving private persons of vested property rights except for a "public use" and upon payment of lust compensat

llant. rI BRIEF FOR DEFENDANT-APPELLANT JAY P. LEFKOWITZ SANDRA LYNN MUSUMECI KnAND & ELLIS LLP 601 Lex

entencing recommendation."); see also People v. Jimenez, 178 Misc. 2d 319, 322-23, 679 N.Y.S.2d 510, 513 (Sup. Ct. Kings Cty. 1998) (observing "the Legislature did not intend to place upon the criminal courts of this State a burden to act merely as a regulatory body to confirm the determination of the Boar

g pursuant to those statues, the caselaw was not clear that all federal victims would liavc been allowed to participate in the state plea hearing. In Lefkowitz’s November 29, 2007 letter to Acosta, he argued tliat Ilie statutes afforded a right to speak at a defendant’s sentencing or to submit a statement on

ignation was;mado,;andjpfpvidcd such person nolongermeets die criteria for registration as a sexual1offender under the laws of thisstoto. ! (12) -The Legislature findsithat.sexualioffenders; especially those who,havexommitted^ffenses, <against'minors;>ofton pose a?high:risk'of engaging in sexual offenses even