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

mes Unit. See A.89-A.90 (Tr.). At the invitation of the District Attorney's Office, counsel for Appellant followed up that meeting by providing for the People's review additional evidence from the Florida investigation to supplement the relatively limited materials provided by the Board. See A.89-A.90 (Tr.)

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

the Sex Crimes Unit rather than the more junior Assistant District Attorney originally assigned to the matter -- advised the Court that based upon the People's investigation and interaction with Florida authorities, the Board materials could not be relied upon in full and therefore did not support a Level

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

mes Unit. See A.89-A.90 (Tr.). At the invitation of the District Attorney's Office, counsel for Appellant followed up that meeting by providing for the People's review additional evidence from the Florida investigation to supplement the relatively limited materials provided by the Board. See A.83, A.89-A.90