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ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the lower court's lega
ting and lurid detail — the very Probable Cause Affidavit that the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA and that was rejected by the Florida prosecutors who handled Appellant's criminal case. Whether this complete abandonment
A is per se not reliable where it is actually proven false, and directly contradicted by non-hearsay evidence. See, e.g., 5 N.Y. Prac., Evidence in New York State and Federal Courts § 8:98 (stating that hearsay "is not immune from impeachment" and that hearsay evidence "may be attacked in any of the usual way
ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the Court's legally in
a prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportabl
e SORA is per se not reliable where it is actually proven false, and directly contradicted by non-hearsay evidence. See, e.g., 5 Prac., Evidence in New York State and Federal Courts § 8:98 (stating that hearsay "is not immune from impeachment" and that hearsay evidence "may be attacked in any of the usual way
nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00231549 women who were seventee
to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari
G. WEINBERG, P.C. ATTORNEY AT LAW 20 PARK PLAZA. SUITE 1000 EMAIL ADDRESSES: BOSTON, MASSACHUSETTS 02116 FAX NIGHT EMERGENCY. August 16, 2010 New York State Board of Examiners of Sex Offenders 4 Tower Place Albany, New York 12203-3764 Re: Jeffrey Epstein NYSID N OS1909 Dear Sir or Madam: MIS This
to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari
nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving EFTA00232669 women who were seventeen y
ust 16, 2010 [pp. A53-A571 MARTIN G. WEINBERG, P.C. ATTORNEY • LAW 20 PARK PLAZA, SUITE 1000 BOSTON. MASSACHUSETTS 02116 FAX August 16, 2010 New York State Board of Examiners of Sex Offenders 4 Tower Place Albany, New York 12203-3764 Re: Jeffrey Epstein NYSID # O51909 • Dear Sir or Madam: EMAIL A
Entities connected to both Appellant and New York State

Jeffrey Epstein
PERSON
New York
LOCATION
United States
LOCATION
Ghislaine Maxwell
PERSON
New York City
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Samantha Power
PERSON
George W. Bush
PERSONLeon Black
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSON
Michael Jackson
PERSON
John F. Kennedy
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSONDarren Indyke
PERSON
Alan Dershowitz
PERSON