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

ppropriate where the apparent impartiality of the lower court has been legitimately questioned, as it most certainly has here. See, e.g., People v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008) (remanding resentencing matter to a different Justice where the "appearance of fairness and impartiality [was]

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

of the matter to a different Justice should this Court deem remand necessary to recalculate Appellant's risk assessment level. See, e.g., People v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008); Fresh Del Monte Produce N.V. u. Eastbrook Caribe, 40 A.D.3d 415, 421 (1st Dep't 2007). 30 EFTA00792603 CON

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

ppropriate where the apparent impartiality of the lower court has been legitimately questioned, as it most certainly has here. See, e.g., People v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008) (remanding resentencing matter to a different Justice where the "appearance of fairness and impartiality [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

ppropriate where the apparent impartiality of the lower court has been legitimately questioned, as it most certainly has here. See, e.g., People v. Rampino, 55 A.D.3d 348, 349 (1st Dep't 2008) (remanding resentencing matter to a different Justice where the "appearance of fairness and impartiality [was]