Epstein Secrets

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

register under SORA, despite not being a resident of New York, because of his ownership of a secondary property in Manhattan.3 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, dated Aug. 16, 2010). Shortly thereafter, Appellant's counsel submitted a letter to the Board outlining

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

m to register under SORA, despite not being a resident of New York, given his ownership of a secondary property in Manhattan.2 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, dated Aug. 16, 2010). Shortly thereafter, in response, Appellant's counsel submitted a letter to the Bo

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

m to register under SORA, despite not being a resident of New York, given his ownership of a secondary property in Manhattan.3 See A.53 (Letter of M. Weinberg to NYS Board of Examiners of Sex Offenders, dated Aug. 16, 2010). Shortly thereafter, Appellant's counsel submitted a letter to the Board outlining