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tected liberty interest that entitles them to procedural due process. See Doe v. Pataki, 3 F. Supp. 2d 456, 468 (S.D.N.Y. 1998); see also People v. David W., 95 N.Y.2d 130, 138 (2000) (holding that the imposition of a Level 3 SORA determination implicates liberty interests and triggers due process safe
EVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW. 17 A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. 20 B. The Court Improperly Relied on the Board's
D.2d 99 (2d Dep't 2003) '31 People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) 24 People v. Curthoys, 77 A.D.3d 1215 (3d Dep't 2010) 27 People v. David W., 95 N.Y.2d 130 (2000) :32 iii EFTA00181029 EFTA00181030 People v. Dominie, 42 A.D.3d 589 (3d Dep't 2007) 19 People v. Donk, 39 A.D.3d 126
EVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW. 17 A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. 20 B. The Court Improperly Relied on the Board's
eople v. Brooks, 308 A.D.2d 99 (2d Dep't 2003) People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) 24 People v. Curthoys, 77 A.D.3d 27 People v. David W., 95 N.Y.2d 130 (2000) 32 iii EFTA00231544 People v. Dominie, 42 A.D.3d 589 (3d Dep't 2007) 19 People v. Donk, 39 A.D.3d 1268 (4th Dep't 200
LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW 17 A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. 20 B. The Court Improperly Relied on the Board's
31 People v. Brooks, 308 A.D.2d 99 (2d Dep't 2003) 31 People v. Coffey, 45 A.D.3d 658 (2d Dep't 2007) 24 People v. Curthoys, 27 People v. David W., 95 N.Y.2d 130 (2000) 32 iii EFTA00232664 People v. Dominie, 42 A.D.3d 589 (3d Dep't 2007) 19 People v. Donk, 39 A.D.3d 1268 (4th Dep't 200
EVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVIDENCE AS REQUIRED BY SORA AND AS A MATTER OF FEDERAL CONSTITUTIONAL LAW. 17 A. The People's Investigation Revealed That The Board's Recommendation Could Not Be Proven By Clear and Convincing Evidence. 20 B. The Court Improperly Relied on the Board's
Entities connected to both David W. and The People's Investigation

Ruth Pickholz
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Adriana Ross
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George W. Bush
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U.S. Virgin Islands
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New York City
LOCATIONJack Goldberger
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Jay Lefkowitz
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Bill Richardson
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Kendall Coffey
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Sarah Ferguson
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Jeffrey Epstein
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