Epstein Secrets

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)

t with M. SG said she was paid three hundred dollars in cash from Epstein. Before she left Epstein asked SO to leave her phone number. As SG, and Figueroa were leaving the house, told SO she received two hundred dollars that day fo bringing her. During the course of the investigation, parental conse

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

met with SG said she was paid three hundred dollars in cash from Epstein. Before she left Epstein asked SG to leave her phone number. As SO, and Figueroa were leaving the house, told SG she received two hundred dollars that day or ringing her. During the course of the investigation, parental consent

R BEYER,LAWRENCE COHLAN,JOHN LEFKOWITZ,ELISE JAMES,JANET B HILL,MELANIE

Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO

compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would

equesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include speci