Epstein Secrets

KIRKLAND & ELLIS LLP MEMORANDUM CONFIDENTIAL TO: ADA Lisa Friel, Chief, Sex Crimes Unit ADA Jennifer Gaffney, Deputy Chief, Sex Crimes Unit ADA Patrick Egan, Sex Cr

hat a Board case summary "may be rejected when it is unduly speculative or its accuracy is undermined by other more compelling evidence." People v. Mingo, 12 N.Y.3d 563, 573 (2009). Here, the case summary prepared by the Board reviewer should be summarily rejected as unduly speculative, unreliable, an

KIRKLAND & ELLIS LLP MEMORANDUM CONFIDENTIAL TO: ADA Lisa Friel, Chief, Sex Crimes Unit ADA Jennifer Gaffney, Deputy Chief, Sex Crimes Unit ADA Patrick Egan, Sex Cr

hat a Board case summary "may be rejected when it is unduly speculative or its accuracy is undermined by other more compelling evidence." People v. Mingo, 12 N.Y.3d 563, 5_ (2009). Here, the case summary prepared by the Board reviewer should be summarily rejected as unduly speculative, unreliable, and

sta, Abdus-Salaam, JJ. 6081 The People of the State of New York, Ind. 30129/10 Respondent, -against- Jeffrey E. Epstein, Defendant-Appellant. Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of counsel), for appellant. Cyrus R. Vance, Jr., District Attorney, New York (Deborah L. Morse of counsel), for respon

ffidavit prepared by Florida law enforcement authorities after their investigation, and the Board of Examiners of Sex Offenders' case summary (see Mingo, 12 NY3d at 572-573, 577). The probable cause affidavit was extremely detailed. It set forth the sworn, tape-recorded statements of the victims. Th

sta, Abdus-Salaam, JJ. 6081 The People of the State of New York, Ind. 30129/10 Respondent, -against- Jeffrey E. Epstein, Defendant-Appellant. Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of counsel), for appellant. Cyrus R. Vance, Jr., District Attorney, New York (Deborah L. Morse of counsel), for respon

ffidavit prepared by Florida law enforcement authorities after their investigation, and the Board of Examiners of Sex Offenders' case summary (see Mingo, 12 NY3d at 572-573, 577). The probable cause affidavit was extremely detailed. It set forth the sworn, tape-recorded statements of the victims. Th

skowitz, Acosta, Abdus-Salaam, JJ. 6081 30129/10 relIThe People of the State of New York, Respondent, V Jeffrey E. Epstein, Defendant-Appellant. Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of EFTA00614180 counsel), for appellant. Cyrus R. Vance, Jr., District Attorney, New York (Deborah L. Morse of couns

affidavit prepared by Florida law enforcement authorities after their investigation, and the Board of Examiners of Sex Offenders' case summary (see Mingo, 12 NY3d at 572-573, 577). The probable cause affidavit was extremely detailed. It set forth the sworn, tape-recorded statements of the victims. Th

y, Moskowitz, = Abdus-Salaam, JJ. 6081 30129/10 (*Wile People of the State of New York, Respondent, I Jeffrey E. Epstein, Defendant-Appellant. Kirkland & Ellis LLP, New York (Jay P. Lefkowitz of EFTA00184585 Case 9:08-cv-80736-KAM Document 361-38 Entered on FLSD Docket 02/10/2016 Page 3 of 5 counsel), for ap

affidavit prepared by Florida law enforcement authorities after their investigation, and the Board of Examiners of Sex Offenders' case summary (see Mingo, 12 NY3d at 572-573, 577). The probable cause affidavit was extremely detailed. It set forth the sworn, tape-recorded statements of the victims. Th