Epstein Secrets

RA hearing had been scheduled to determine a risk assessment level, accompanied by a copy of the recommendation of the Board. See A67 (Letter from Supreme Court, dated Aug. 26, 2010); A.65 (Recommendation of Board of Examiners of Sex Offenders ("Board Recommendation").). In stark contrast to the other

y interests and triggers due process safeguards). Courts evaluating that liberty interest under the procedural due process analysis articulated by the U.S. Supreme Court in Matthews v. Eldridge, 424 U.S. 319 (1976) (balancing the private interest affected by state action, the risk of erroneous deprivation of that i

g evidence, to wit, the undisputed conduct encompassed by Appellant's registerable crime of conviction. February 22, 2011 Respectfully submitted, Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein E

tified that the Board had recommended a Level 3 classification and that a SORA hearing was scheduled for September 15, 2010. See A.68 (Letter from Supreme Court to Jeffrey E. Epstein Informing of SORA Level Determination Hearing, dated Aug. 26, 2010); A.71-A.76 (Letter from Supreme Court to Counsel Informin

level should be recalculated in accordance with the law. September 16, 2011 Respectfully submitted, /s/ Jay P. Lefkowitz Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRICLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein 4

Level 3 determination falls short of the minimum due process rights guaranteed by the U.S. Constitution. In the landmark case of Goldberg a Kelly, the U.S. Supreme Court held that, in relevant part, to demonstrate compliance with the procedural due process requirement 47 EFTA00181129 EFTA00181130 that the decis

program (McAfee Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. Jay p. efkowitz, P.C. Sandra Lynn Musumeci KIRKIAAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone Facsimile: EFTA00181137 EFTA00181138 . EFTA00181139 EFTA00

Level 3 determination falls short of the minimum due process rights guaranteed by the U.S. Constitution. In the landmark case of Goldberg v. Kelly, the U.S. Supreme Court held that, in relevant part, to demonstrate compliance with the procedural due process requirement 47 EFTA00231594 that the decision maker's con

program (McAfee Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. Jay PJLefkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: EFTA00231598 SUPREME COURT FOR THE STATE OF NEW YORK