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

Less than two weeks later, on August 26, 2010, Appellant 3 It bears noting that Appellant had already been voluntarily registered with New York's Sexual Offender Monitoring Unit (SOMU) since May 2010. See, e.g., A.88-A.89 (Tr.). 12 EFTA00792585 was notified that the Board had recommended a Level 3 classification and tha

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

ng Appellant's personal background as an accomplished and 2 It bears noting that Appellant had already been voluntarily registered with New York's Sexual Offender Monitoring Unit (SOMU) since May 2010. See, e.g., A.88-A.89 (Pr.). 13 EFTA00798133 respected financial advisor and philanthropist, acceptance of responsibili

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

nt's personal background as an accomplished and respected 3 It bears noting that Appellant had already been voluntarily registered with New York's Sexual Offender Monitoring Unit (SOMU) since May 2010. See, e.g., A.88-A.89 (Pr.). 12 EFTA00584112 financial advisor and philanthropist, acceptance of responsibility for his o