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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
Sex Offender Registration Act: Risk Assessment Guidelines and Commentary, Commentary at 5, ¶ 7 (2006). Accordingly, the Order 6 By previewing for the Appellate Court "[t]he People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See Mount Lucas
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
he People's Attempt to Introduce Materials Outside the Record Was Improper and Reference to Such Contentions Should Be Stricken. By previewing for the Appellate Court in their brief "the People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See
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
to which Appellant ultimately pled guilty.5 Resp. Br. at 62, n. 7. By so doing, the People themselves unwittingly concede that 5 By previewing for the Appellate Court "the People's evidence on remand," see Resp. Br. at 62, n. 7, the People have improperly introduced materials dehors the record. See Mount Lucas As
stlaw. 76912d 389 769 2d 389 Fla. L. Weekly D2439 (Cite as: 769 ..241 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appel lee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties agreed to modification of
Defendant, Mr. Epstein, and his attorney an opportunity to have this Court's orders reviewed by the 4th DCA. If the Clerk gets no direction front the Appellate Court, she shall disclose the documents on the date referred to-above. DONE AND ORDERED in West Palm Beach, Palm BeachsiCGoNuZ,Zi ldr aE tp ED ~tND JU
Entities connected to both Appellant and the Appellate Court

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Supreme Court
ORGANIZATION
United States
LOCATIONScott Rothstein
PERSON
Palm Beach County
LOCATION
New York
LOCATION
James Baker
PERSONGoldberger & Weiss
ORGANIZATIONthe Southern District
LOCATION
New York City
LOCATIONRobert D. Critton
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSON
Barry Diller
PERSON
Jay Lefkowitz
PERSONPalm Beach County Courthouse
LOCATION