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

t. 2010) (observing "the risk level designated in the RAI is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey Epstein presents a negligible risk of r

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

t. 2010) (observing "the risk level designated in the RAI is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey Epstein presents a negligible risk of r

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

t. 2010) (observing "the risk level designated in the RAI is merely presumptive, and a court may depart from it as a matter of discretion") (citing People v. Mingo, 12 N.Y.3d 563, 568 n.2 (2009); People v. Johnson, 11 N.Y.3d 416, 418, 421 (2008)). As noted above, Jeffrey- Mr. Epstein presents a negligible risk

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

" and that hearsay evidence "may be attacked in any of the usual ways"). The People acknowledge as much in their citation and repeated reference to People v. Mingo, 12 N.Y.3d 563, 577 (2009) (noting the unreliability of a victim's statement where it is "equivocal, inconsistent with other evidence, or seems dub