Epstein Secrets

to speak to me or need any further information, please feel free to contact me. V JAG/slm s, Jack A. Goldberger EFTA00231498 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Se: Offenders Regarding Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 [pp. A53-A

berger EFTA00231498 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Se: Offenders Regard

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00231549 women who were seventee

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

14 As Amicas cuicmie: , ESQ. 15 Assistant U.S. Attorney 500 East Broward Boulevard 16 Fort Lauderdale, FL 33394 For U.S.A. 954.356.7255 17 MARTIN G. WEINBERG, ESQ. 18 20 Park Plaza Boston MA 02116 19 (Via telephone) 20 JAY LEFKOWITZ, ESQ. (Via telephone) 21 REPORTED BY: LARRY HERR, RPR-RMR-FCRR-

3 MR. CRITTON: Your Honor, we have two members of the 14 defense team are on the phone, also. 15 THE COURT: Who do we have on the phone? 16 MR. WEINBERG: Martin Weinberg. Good morning, Your 17 Honor. 18 MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your 19 Honor. 20 THE COURT: Good morning. 21 I

y in its response to hearing the District Attorney disavow the reliability of the Board's recommendation, in receiving the arguments of counsel for Appellant, and in rendering its Order as a whole. First, although the SORA statute clearly contemplates that the District Attorney may depart from the Board'

many SORAs much less troubling than this one where the People would never make a downward departure like this.16 A.84:21-85:10 (Tr.). Later, when Appellant's counsel disputed that there were any credible -- much less prosecuted -- allegations that Appellant ever used force, the Court again began compar

to speak to me or need any further information, please feel free to contact me. V JAG/slm s, Jack A. Goldberger EFTA00232618 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regarding Risk Level and Designation Determination for Jeffrey Epstein, dated August 16, 2010 [pp. A53-A

berger EFTA00232618 A53 Letter from Martin G. Weinberg to NYS Board of Examiners of Sex Offenders Regard

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving EFTA00232669 women who were seventeen y

in New York and Florida. See A.53 (Letter of M. Weinberg of Aug. 16, 2010).' Appellant does not live in N

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00792351 women who were seventee

property in Manhattan.3 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, date

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the lower court's lega

ting and lurid detail — the very Probable Cause Affidavit that the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA and that was rejected by the Florida prosecutors who handled Appellant's criminal case. Whether this complete abandonment

property in Manhattan.2 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, date

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the Court's legally in

a prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportabl

property in Manhattan.3 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, date

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the Court's legally in

a prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportabl

in New York and Florida. See A.53 (Letter of M. Weinberg of Aug. 16, 2010).1 Appellant does not live in Ne

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00181039 EFTA00181040 women wh

the existence of cancer, the personal testimony of the lay sufferer is entitled to no weight...... 4I Furthermore, as the Supreme Court found in Weinberger v. Hynson, Westeott and Dunning, Ine.,43: (FDA's] strict and demanding standards, barring anecdotal evidence indicating that doctors "believe" in

Cir. 1993) further findings and reconsideration in actor- justice to grant transfer. dance with the foregoing. § 6032. UNITED STATES of America, Appellant, I Lemrick NELSON, Jr., Defendant- Appellee. No. 421, Docket 95-1271. United States Court of Appeals, Second Circuit. Argued Aug. 29, 1996. De