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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
ease and permitted him to leave the jail and report to work on a daily basis from October 2008 until his release in July 2009. See Letter of Deputy K. Smith of August 12, 2010 (Exhibit E). • While serving his year of community control, both the Court and Mr. Epstein's probation officer granted Mr. Epst
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
ogram and permitted him to leave the jail and report to work on a daily basis from October 2008 until his release in July 2009. See Letter of Deputy K. Smith of August 12, 2010 (Exhibit A). While serving his year of community control, both the Circuit Court in Palm Beach and Mr. Epstein's assigned probat
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
ease and permitted him to leave the jail and report to work on a daily basis from October 2008 until his release in July 2009. See Letter of Deputy K. Smith of August 12, 2010 (Exhibit E). • While serving his year of community control, both the Court and Mr. Epstein's probation officer granted Mr. Epst
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
October 10, 2008, through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release program, see Letter of Deputy K. Smith, Ex. D, which permitted him to leave the jail in the morning six days a week for his place of employment, the Florida Science Foundation, and return
ge 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(2)(a)(i)(§230.04 a registerable offense only if "person patronized" is in fact under 17 ears old). Indeed, at the time of the offense at
October 10, 2008, through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release program, see Letter of Deputy K. Smith, Ex. , which permitted him to leave the jail in the morning six days a week for his place of employment, the Florida Science Foundation, and return
Sandra Lynn Musumeci DATE October 5, 2010 SUBJECT: SORA Determination for Jeffrey E. Epstein, NYSID # OSI909, Supreme Court Case # 30129-2010 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
gram and permitted him to leave the jail and report to work on a daily basis from October 2008 until his release in July 2009. See Letter of Deputy K. Smith of August 12, 2010 (Exhibit A). While serving his year of probation, both the Circuit Court in Palm Beach and Mr. Epstein's assigned probation offic
tted by the court, with the assent of his probation officer and without opposition by the state's attorney, to travel (including overnight stays) to New York and to the Virgin Islands for business purposes on a number of occasions, thus demonstrating a substantial level of trust by both the court and his
October 10, 2008; through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release program, see Letter of Deputy K. Smith, Ex. , which permitted him to leave the jail in the morning six days a week for his place of employment, the Florida Science Foundation, and return
ge 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(2)(a)(i)(§230.04 a registerable offense only if "person patronized" is in fact under 17 ears old). Indeed, at the time of the offense at
October 10, 2008, through July 22, 2009, the date of his release, Mr. Epstein participated in the jail's work release program, see Letter of Deputy K. Smith, Ex. , which permitted him to leave the jail in the morning six days a week for his place of employment, the Florida Science Foundation, and return
Entities connected to both New York and K. Smith

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATION
Stephen Hawking
PERSON
New York State
LOCATION
Scarlett Johansson
PERSONMartin Weinberg
PERSONJack Goldberger
PERSONFederal Bureau of Prisons
ORGANIZATION
Kansas
LOCATION
Jay Lefkowitz
PERSONAlbany
LOCATION
NBC
ORGANIZATIONKirkland & Ellis LLP
ORGANIZATION
Ruth Pickholz
PERSON
Shanghai
LOCATIONV.I.C.
ORGANIZATION
Palo Alto
LOCATIONStephen Alexander
PERSON
Jennifer Gaffney
PERSONFlorida Science Foundation
ORGANIZATION