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KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 601 Lexington Avenue New York. New York 10022 Jay P. Lefkowitz, To Call Writer Directly: (212) 446-4800 Facsimile: (212)446-4970 October 26, 2010 By E-mail CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bure
exington Avenue New York. New York 10022 Jay P. Lefkowitz, To Call Writer Directly: (212) 446-4800 Facsi
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.
KIRKLAND & ELLIS LLP AND AFFILIATED PARTNERSHIPS 601 Lexington Avenue New York. New York 10022 Jay P. Lefkowitz, P.C. (212)446-4800 Facsimile: winv.kIrkland.com October 27, 2010 By E-mail and By Hand CONFIDENTIAL Jennifer Gaffney, Esq. Deputy Bureau Chi
exington Avenue New York. New York 10022 Jay P. Lefkowitz, P.C. (212)446-4800 Facsimile: winv.kIrkland.c
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
re for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In
omptly retained New York counsel and sought a brief adjournment to provide counsel an opportunity to prepare for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorn
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 Jay Lefkowitz and Recarey Dep

Jeffrey Epstein
PERSONKirkland & Ellis LLP
ORGANIZATION
New York
LOCATION
Munich
LOCATIONJoe Recarey
PERSON
Ruth Pickholz
PERSONMySpace
ORGANIZATION
Shanghai
LOCATIONSandra Lynn Musumeci
PERSON
Palo Alto
LOCATIONNew York District
LOCATIONSex Crimes Unit
ORGANIZATION
Jennifer Gaffney
PERSONFelony Solicitation for Prostitution
ORGANIZATIONPatrick M. Regan
PERSONSex Crimes Unit / Trial Bureau
ORGANIZATIONADA Egan
ORGANIZATIONRecarey Probable Cause
ORGANIZATIONthe New York State Department of Taxation
ORGANIZATIONPersonal Income Tax Audit Changes
ORGANIZATION