Epstein Secrets

e rating of Level 3, without meaningful inquiry into any of the underlying allegations or any consideration of other evidence which could bear upon Appellant's risk level. See A.93:21, 94:6-96:9, 96:11-13 (Pr.). 44 EFTA00181123 EFTA00181124 III. THE COURTS ORDER DOES NOT COMPLY WITH THE MANDATES OF

er of the New York Supreme Court determining Appellant Jeffrey E. Epstein to be a Level 3 sex offender, without designation, should be vacated, and Appellant's SORA level should be recalculated -- either by this Court based on the present record or upon remand to a different Justice in the lower court -

ew York 10022-4611 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NY 10013 Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), Ne

y in its response to hearing the District Attorney disavow the reliability of the Board's recommendation, in receiving the arguments of counsel for Appellant, and in rendering its Order as a whole. First, although the SORA statute clearly contemplates that the District Attorney may depart from the Board'

many SORAs much less troubling than this one where the People would never make a downward departure like this.16 A.84:21-85:10 (Tr.). Later, when Appellant's counsel disputed that there were any credible -- much less prosecuted -- allegations that Appellant ever used force, the Court again began compar

phone: Facsimile: 4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT: Cyrus R. Vance, Jr. NEW YORK DISTRICT ATTORNEY'S OFFICE One Hogan Place New York, NYilli m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New

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

Z Justice of the Supreme Court 13 14 APPEARANCES: 15 16 For the People: CYRUS R. VANCE, JR., ESQ., New York County District Attorney 17 One Hogan Place NewY York 10013 18 BY: GAFFNEY, ESQ. Assis an strict Attorney 19 For the Defense: KIRKLAND & ELLI, LLP 20 153 East 53rd Street 21 New