Epstein Secrets

ESTIONS PRESENTED STATEMENT OF FACTS 3 I. The Underlying Offense 4 II. Sex Offender Registration 6 III. The Board's Recommendation 7 IV. Pre-Hearing Investigation By the District Attorney 11 V. SORA Hearing 12 ARGUMENT 16 I. THE COURT'S LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVI

privation of liberty or stigma," due process demands "more than average certainty on the part of the factfinder." E.B., 119 F.3d at 1110-11 (citing Santosky v. Kramer, 455 U.S. 745, 756- 58 (1982)). Accordingly, "registrants are entitled to have the burden of persuasion placed on the state, with the state obligate

IONS PRESENTED 2 STATEMENT OF FACTS 3 I. The Underlying Offense 4 II. Sex Offender Registration 6 III. The Board's Recommendation 7 IV. Pre-Hearing Investigation By the District Attorney 11 V. SORA Hearing 12 ARGUMENT 16 I. THE COURT'S LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVI

privation of liberty or stigma," due process demands "more than average certainty on the part of the factfinder." E.B., 119 F.3d at 1110-11 (citing Santosky v. Kramer, 455 U.S. 745, 756- 58 (1982)). Accordingly, "registrants are entitled to have the burden of persuasion placed on the state, with the state obligate

IONS PRESENTED 2 STATEMENT OF FACTS 3 I. The Underlying Offense 4 II. Sex Offender Registration 6 III. The Board's Recommendation 7 IV. Pre-Hearing Investigation By the District Attorney 11 V. SORA Hearing 12 ARGUMENT 16 I. THE COURT'S LEVEL 3 DETERMINATION IS NOT SUPPORTED BY CLEAR AND CONVINCING EVI

eprivation of liberty or stigma," due process demands "more than average certainty on the part of the factfmder." E.B., 119 F.3d at 1110-11 (citing Santosky v. Kramer, 455 U.S. 745, 756- 58 (1982)). Accordingly, "registrants are entitled to have the burden of persuasion placed on the state, with the state obligate