Epstein Secrets

mptly 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. 7, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorne

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

ssumed by him, at least where he had, or was chargeable with, full knowledge of the facts and another will be prejudiced by his action."); see also Kilcer v. Niagara Mohawk Power Corp., 86 A.D.3d 682, 682 (3d Dep't 2011) (observing "the litigant should be bound by the prior stance that he or she clear

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

's improper Level 3 SORA adjudication stands in stark contrast to the People's position at the SORA hearing itself and should not be permitted. See Kilcer v. Niagara Mohawk Power Corp., 86 A.D.3d 682, 682 (3d Dep't 2011) ("A litigant should not be permitted to lead a tribunal to find a fact one way an

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

are for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In

3 4 EFTA00584104 SORA adjudication stands in stark contrast to the People's position at the SORA hearing itself and should not be permitted. See Kilcer v. Niagara Mohawk Power Corp., 86 3d 682, 682 (3d Dep't 2011) ("A litigant should not be permitted to lead a tribunal to find a fact one way and