Epstein Secrets

THER JURISDICTION. 10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION. Dated: January 24, 2011 Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexin on Avenue Attorneys for Defendant-Appellant Jeffrey E. Esptein. -2- EFTA00589580

on of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of EFTA00589579 discretion and constituted reversible legal error, as the District Attorney's Office agreed that there was not clear and convincing evidence to support a Level 3 designation. 9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PE

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

evel I Under SORA Will More Than Adequately Protect The People Of New York From Any Negligible Threat Posed By Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that the intentions of SORA will be fully realized by imposing on Jeffrey Epstein a Level 1 designation for his Florida

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

ORA Will More Than Adequately Protect the People of the State of New York from Any Negligible Threat Posed by Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that intentions of SORA will be fully realized by imposing on Jeffrey Epstein a Level 1 designation for his Florida conv

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

evel I Under SORA Will More Than Adequately Protect The People Of New York From Any Negligible Threat Posed By Jeffrey Epstein To come full circle, the District Attorney's Office should take comfort that the intentions of SORA will be fully realized by imposing on Mr. Jeffrey-Epstein a Level 1 designation for his Flor

ORA level should be recalculated in accordance with the law. September 16, 2011 Respectfully submitted, Jay P. Le owitz. P Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 Counsel for Defendant-Appellant Jeffrey E. Ep

pellant did not have a meaningful opportunity to present evidence on his own behalf because 1 As set forth in greater detail in Section II, infra, the District Attorney's Office was presented with, and had already considered, much of this countervailing evidence as part of its pre-hearing investigation and discussion

hange in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New Ynrk 10022-4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyr

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre

hange in the parties. 3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER: Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, Ne 4611 Telephone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance,

ocedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agre