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ing obligations, or in the case of New Mexico, not required to register at all under the state's sex offender registration scheme. (Notwithstanding New Mexico's determination that he need not register at all, Mr. Epstein has voluntarily chosen to register in New Mexico in order to ensure his full compliance
citizens of New York. See Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary (2006) at 4, ¶ 5; see also People v. Ferrer, 69 M3d 513, 514 (1st Dept. 2010) (observing "the risk level designated in the RAI is merely presumptive, and a court may depart from it as a matter
rk vacation home and who is already being sufficiently monitored by the authorities of the U.S. Virgin Islands (his home jurisdiction), Florida, and New Mexico -- all by virtue of the fact that he owns property in those places. Under New York law, as a Level 1 sex offender, Jeffrey Mr. Epstein will be requ
xpertise to the offender. Sex Offender Registration Act: Risk Assessment Guidelines and Commentaiy, Commentary (2006) at 4, ¶ 5; see also People v. Ferrer, 69 A.D.3d 513, 514 (1st Dept. 2010) (observing "the risk level designated in the RAI is merely presumptive, and a court may depart from it as a ma
d as "1 female." Exhibit 27. Who is that "female" — and what is her age? Similarly, Jane Doe No. 3 appears on a July 16, 2001, flight from Santa Fe, New Mexico to Teterboro, New Jersey, along with Epstein, Maxwell and Emmy Tayler. Yet there is no earlier flight that would have landed Jane Doe No. 3 in New M
ourt's anticipated approval. Three months later, having received no response from the Government, victims' counsel sent an additional letter to Mr. Ferrer, requesting agreement to add an additional victim to the case — a young woman identified in current pleadings as Jane Doe No. 34: Dear Mr. Ferrer:
explained that the infor ontained hundreds of additional victims and their phone numbers from diverse geographic locations including New York, New Mexico and Paris," according to the affidaui ratgne Also reasons named is scheduled to be ar- ederal court Monday. ffidavit are the cited to the un-
Professor of Criminal Law Telephone: 801-585-5202 [email protected] Re: Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80736 Dear Mr. Ferrer: We are writing to you personally on behalf of Jane Doe #1 and Jane Doe #2 in one last effort to try and narrow our range of difference in the pend
d as "1 female." Exhibit 27. Who is that "female" — and what is her age? Similarly, Jane Doe No. 3 appears on a July 16. 2001, flight from Santa Fe, New Mexico to Teterboro, New Jersey. along with Epstein, Maxwell and Yet there is no earlier flight that would have landed Jane Doe No. 3 in New Mexico. Accor
ourt's anticipated approval. Three months later, having received no response from the Government, victims' counsel sent an additional letter to Mr. Ferrer. requesting agreement to add an additional victim to the case — a young woman identified in current pleadings as Jane Doe No. 34: Dear Mr. Ferrer:
Entities connected to both New Mexico and Ferrer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Bradley Edwards
PERSONLeon Black
PERSONJane Doe
PERSON
Paul Cassell
PERSON
New York
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Santa Fe
LOCATIONFBI
ORGANIZATION
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Marc Rich
PERSON
Prince Andrew
PERSON
Palm Beach
LOCATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON