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45 A.D.3d 429 (1st Dept. 2007) 36 People v. Mingo, 12 N.Y.3d 563 (2009) 36-37, 40 People v. O'Neal, 35 A.D.3d 302 (1st Dept. 2006) 36 People v. Pettigrew, 14 N.Y.3d 406 (2010) 36 People v. Roland, 292 A.D.2d 271 (1st Dept. 2002) 38 People v. Smith, 75 A.D.3d 1112 (4th Dept. 2010) 58 People v. Vas
DEBORAH'. MORSE ASSISTANT DISTRICT ATTORNEYS Of Counsel EFTA00602338 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ii INTRODUCTION 1 POINT THE SORA COURT'S DESIGNATION OF DEFENDANT AS A LEVEL-THREE OFFENDER WAS SUPPORTED OVERWHELMINGLY BY THE RECORD. THE PROCESS BY WHICH THE COURT REACHED AND DELIVER
45 A.D.3d 429 (1st Dept. 2007) 36 People v. Mingo, 12 N.Y.3d 563 (2009) 36-37, 40 People v. O'Neal, 35 A.D.3d 302 (1st Dept. 2006) 36 People v. Pettigrew, 14 N.Y.3d 406 (2010) 36 People v. Roland, 292 A.D.2d 271 (1st Dept. 2002) 38 People v. Smith, 75 A.D.3d 1112 (4th Dept. 2010) 58 People v. Vas
DEBORAH L MORSE ASSISTANT DISTRICT ATTORNEYS Of Counsel EFTA00792500 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ii INTRODUCTION 1 POINT THE SORA COURT'S DESIGNATION OF DEFENDANT AS A LEVEL-THREE OFFENDER WAS SUPPORTED OVERWHELMINGLY BY THE RECORD. THE PROCESS BY WHICH THE COURT REACHED AND DELIVER
hat the risk factors giving rise to the offender's score were supported by "dear and convincing evidence." ,egg Correction Law §168- n(3); People v. Pettigrew, 14 N.Y.3d 406, 408 (2010); People v. O'Neal. 35 A.D.3d 302 (1st Dept 2006). That SORA employs this relatively-relaxed standard, as opposed to proo
EBORA!! L MORSE ASSISTANT DISTRICT ATTORNEYS Of Counsel EFTA00181147 TABLE OF CONTENTS if' g TABLE OF AUTHORITIES ii INTRODUCTION 1 POINT THE SORA COURT'S DESIGNATION OF DEFENDANT AS A LEVEL-THREE OFFENDER WAS SUPPORTED OVERWHELMINGLY BY THE RECORD. THE PROCESS BY WHICH THE COURT REACHED AND DELIVER
Entities connected to both Pettigrew and THE SORA COURT'S

Jeffrey Epstein
PERSONSouthern District
LOCATION
New York City
LOCATION
Alfredo Rodriguez
PERSON
The Palm Beach Post
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Juan Alessi
PERSON
Sarah Ferguson
PERSON
Western Union
ORGANIZATION
Legislature
ORGANIZATION
McGuire
PERSON
U.S. Virgin Islands
LOCATIONFelony Solicitation of Prostitution
ORGANIZATIONGuaman
PERSONPeople v. Kello
PERSONAppellate Division - First Department
ORGANIZATIONthe State of New York Board of Examiners of Sex Offenders
ORGANIZATIONthe SORA Board
ORGANIZATIONThe Florida Probable-Cause
ORGANIZATIONThe Recommendations Of The Board
ORGANIZATION