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s scheduled to appear before the Honorable Ruth Pickholz in New York Supreme Court, Part 66, on Tuesday, November 9, 2010 for a hearing pursuant to New York's Sex Offender Registration Act (SORA), Correction Law § 168 et seq.. We respectfully submit this letter and the accompanying materials for your cons
of all, because the offense which triggered the registration requirement in Florida — and then, solely by virtue of Correction Law § 168-a(d)(2), in New York — would not have been a registerable offense at all (and almost certainly would have only been a misdemeanor) had it been committed in New York inst
up from being a college drop-out to become a highly successful financial advisor, as well as founder and patron of the C.O.U.Q Foundation Inc. and Enhanced Education, charitable organizations which, among other things, fund numerous philanthropic entities, educational grants and activities, as well as medical and
igned To Impose Reporting Requirements Upon Offenders In Proportion To The Threat They Pose To The Public So That They May Be Adequately Monitored New York's Sex Offender Registration Act (SORA), Correction Law § 168 et aL is intended to impose the most stringent reporting requirements on those sex offend
registration requirements here in New York -- if indeed it qualifies as registerable at all. At most, Mr. Epstein was guilty of a misdemeanor under New York law, and accordingly, his registration obligations under SORA should reflect this relative lack of severity of his offense. Even under the broader
iddle- class Brooklyn neighborhood to become a highly successful financial advisor, as well as founder and patron of the C.O.U.Q Foundation Inc. and Enhanced Education, charitable organizations which, among other things, fund numerous philanthropic entities, educational grants and activities, as well as medical an
d the reasoned determinations of other jurisdictions having greater contact and control over Mr. Epstein, the Board of Examiners of Sex Offenders in New York has recommended that Mr. Epstein be categorized as a Level 3 sex offender. Such a harsh designation would subject Jeffrey Epstein to a lifetime obli
oted that the New York cognate of this crime, Promoting Prostitution in the Third Degree, P.L. § 230.25, is not itself a registerable offense under New York's New York's Sex Offender Registration Act (SORA), Correction Law § 168-a(2). Moreover, the conduct underlying this conviction -- a consensual arrange
up from being a college drop-out to become a highly successful financial advisor, as well as founder and patron of the C.O.U.Q Foundation Inc. and Enhanced Education, charitable organizations which, among other things, fund numerous philanthropic entities, educational grants and activities, as well as medical and
n the Information, he received massages and engaged in sexual touching in exchange for money with A.D., a young woman over the age of consent under New York law for all but two months of the fourteen month period during which this conduct is alleged to have occurred Asut--just-under--1-8-fer--all-but-two
ng Requirements Upon Offenders In Proportion To The Threat They Pose To The Public So That They May Be Adequately Monitored As you are well aware, New York's Sex Offender Registration Act (SORA), Correction Law § 168 et at is intended to impose the most stringent reporting requirements on those sex offen
ddle- class Brooklyn neighborhood to become a highly successful financial advisor, as well as founder and patron of Tthe C.O.U.Q Foundation Inc. and Enhanced Education, charitable organizations which, among other things, fund numerous philanthropic entities, educational grants and activities, as well as medical an
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
ompanies and non-profit organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, an
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
ompanies and non-profit organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, an
Entities connected to both New York and Enhanced Education

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
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Virginia Giuffre
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Marc Rich
PERSONDarren Indyke
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U.S. Virgin Islands
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Prince Charles
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George Mitchell
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Stephen Hawking
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Lesley Groff
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Palm Beach
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Richard Kahn
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Les Wexner
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Scarlett Johansson
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Lawrence Krauss
PERSONJack Goldberger
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