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y follows that the Due Process Clause requires that the state prove its case by clear and convincing evidence in a Megan's Law proceeding. B.B. v. Verniero, 119 F.3d 1077, 1111 (3d Cir. 1997), art. denial, 622 U.S. 1109 (1998) (citing Addington v. Texas, 441 U.S. 418, 427 (1979)); see also
age of 17, and the wholly consensual conduct in exchange for money which occurred between the two would not even have been a registerable offense in New York. See §168-a(2XaXi)(§230.04 a registerable offense only if "person patronized" is in fact under 17 years old). Indeed, at the time of the offense at
and order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C, based on a 2008 Florida conviction by plea of guilty to Procuring a Person Und
OBBIE M. MCKENNA ASHLIE SICKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK Of COUNSEL EDWARD M. RJCCI SPtCIM CONSUMER JUSTICE COUNSEL Re: B.B. v. Jeffrey Epstein, et al. Case No. 502008CA037319XXXX MBAB 1/26/10, 8:10 a.m. - 30-minute Special Set Hearing on Defendant Epstein's Motion for S
uvin has made statements to the media which have been published in the following articles, television broadcasts and on the following websites: a. New York Post, December 28, 2009, http://www.nvpost.com/p/papesix/babes suing epstein feel heat CaiFdOphotZWMvhGGXvxWL b. Sun Sentinel, December 22,
e materials. The Government has already followed this procedure elsewhere and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B."). No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the Government are represented by undersigned counsel and do no
003546 Thru P-003552 Box #1 P-003553 Thru P-003555B Description FBI Reports of March 2008 interviews of additional witness/victim located in New York Printout of filenames from Federal Express subpoena response with Attorney notations Privilege(s) Asserted Work product 6(e) Contains informati
Entities connected to both B.B. and New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATION
John F. Kennedy
PERSON
New York City
LOCATION
U.S. Virgin Islands
LOCATION