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w York has even less of a basis to adjudge Mr. Epstein as anything other than the lowest level offender -- Level 1 under SORA -- than do Florida and the U.S. Virgin Islands. Whereas Mr. Epstein maintains his permanent residence in the Virgin Islands and spends most of his time there, and Florida was the site of the off
t 9, 2010 when he returned to the U.S. Virgin Islands upon completing his period of community control in Florida. Mr. Epstein first registered with Virgin Island authorities upon his release from incarceration. 4 K&E 17760332.3 EFTA00722430 KIRKLAND & ELLIS LLP Justice before leaving, and must also regis
his SORA designation reflect that fact. B. The Level 3 Calculation by the Board Is Not Supported by Facts or the Law Curiously, the reviewer from the Board of Examiners of Sex Offenders recommended that Jeffrey Epstein be designated a Level 3 offender, notwithstanding the absence of any key factors that suggesting that he might pos
that have already considered Mr. Epstein's risk level under their own sex offender reporting schemes, as set forth in greater detail below: • In the U.S. Virgin Islands, where Jeffrey Epstein maintains his permanent residence and spends the bulk of his time, Mr. Epstein qualifies at the lowest level as a "sex offend
t 9, 2010 when he returned to the U.S. Virgin Islands upon completing his period of community control in Florida. Mr. Epstein first registered with Virgin Island authorities upon his release from incarceration. 3 K&E 17828669.1 EFTA00722443 KIRKLAND & ELLIS LLP • Florida -- where Jeffrey Epstein was act
th to abide by the law unconditionally, and the reasoned determinations of other jurisdictions having greater contact and control over Mr. Epstein, the Board of Examiners of Sex Offenders in New York has recommended that Mr. Epstein be categorized as a Level 3 sex offender. Such a harsh designation would subject Jeffrey Epstein to a
909, Supreme Court Case # 30129-2010 Jeffrey Epstein is ;4 57-year old financial advisor and philanthropist who maintains his primary residence in the U.S. Virgin Islands where he spends the majority of his time. He spends -limited time at but-owns-a-vacation homes in Manhattan, New Mexico and Florida. In connection
e Virgin Islands Sexual Offender/Sexual Predator Registration Form, August 9. 2010 (Exhibit D):3 see also 14 V.I.C. 1722(b), 1724(d). Moreover, the Virgin Islands explicitly mandates that should Mr. Epstein move out of the U.S. Virgin Islands, he must register his new address with the U.S. Virgin Islands Depar
& ELLIS LLP demonstrated a commitment to go beyond what is demanded of him to remain in full compliance with the law. Curiously, the reviewer from the Board of Examiners of Sex Offenders recommended that Mr. Jeffrey-Epstein be designated a Level 3 offender, notwithstanding the absence of any key factors that even remotely suggesting
Entities connected to both U.S. Virgin Islands and the Board of Examiners of Sex Offenders

Jeffrey Epstein
PERSONDarren Indyke
PERSON
United States
LOCATION
Richard Kahn
PERSON
New York
LOCATION
Financial Trust Company
ORGANIZATION
Alan Dershowitz
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Palm Beach
LOCATION
Department of Justice
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
New York City
LOCATIONJack Goldberger
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON