Epstein Secrets

NEW YORK, —against— JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. BRIEF FOR DEFENDANT-APPELLANT JAY P. LE•FKOWITZ SANDRA LYNN MUSUMECI KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Attorneys for Defendant-Appellant REPRODUCED ON RECYCLED PAPER EFTA00792343 TABLE OF CONTENTS P

supporting reasons. See People v. Ferguson, 53 A.D.3d at 572 (reversing SORA order where defendant and court did not receive proper 10-day notice of People's revised RAI); cf. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was

ed conduct encompassed by Appellant's registerable crime of conviction. February 22, 2011 Respectfully submitted, Sandra nn Musumeci kland.com KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein EFTA00231596 PRINTING

nd review a written statement of the People's recommended determination and order where defendant and court did not receive proper 10-day notice of People's revised RAI); cf. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was

Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 09/07/2010 09:55 FAX 0 2:00 2 KIRKLAND & ELLIS LLP NIO arnuarrn PAItTNIRSHIPS 601 Lexington Avenue Now York. NkY/ Yolk 10022 Jay P LelkowItz,. To Call WIWI Dimly: Facsinne awn.. kiridandccm BY

nd review a written statement of the People's recommended determination and order where defendant and court did not receive proper 10-day notice of People's revised RAI); ef. People v. Jordan, 31 A.D.3d 1196, 1196 (4th Dep't 2006) (holding People's failure to provide sufficient notice of revised RAI was