Epstein Secrets

urt's file. See Appendix generally. V. SORA Hearing On January 18, 2011, a SORA hearing was conducted in New York Supreme Court, Criminal Term, New York County, Part 66 before Hon. Ruth Pickholz. See A.81 (Handwritten Notations on Court Jacket); A.82 (Tr. generally). At the hearing, the People made a reco

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00792351 women who were seventee

the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the lower court's lega

ting and lurid detail — the very Probable Cause Affidavit that the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA and that was rejected by the Florida prosecutors who handled Appellant's criminal case. Whether this complete abandonment

the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the Court's legally in

a prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportabl

the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Articl

ood that the SORA hearing would be a non-adversarial proceeding with no opportunity or need to present evidence. For the People now to suggest that Appellant erred "as a tactical matter" in trusting the prosecutor's word, and moreover, should be procedurally barred from challenging the Court's legally in

a prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportabl

urt's file. See Appendix generally. V. SORA Hearing On January 18, 2011, a SORA hearing was conducted in New York Supreme Court, Criminal Term, New York County, Part 66 before Hon. Ruth Pickholz. See A.81 (Handwritten Notations on Court Jacket); A.82 (Tr. generally). At the hearing, the People made a reco

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00181039 EFTA00181040 women wh

ce New York, NY 10013 Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of th

e rating of Level 3, without meaningful inquiry into any of the underlying allegations or any consideration of other evidence which could bear upon Appellant's risk level. See A.93:21, 94:6-96:9, 96:11-13 (Pr.). 44 EFTA00181123 EFTA00181124 III. THE COURTS ORDER DOES NOT COMPLY WITH THE MANDATES OF

er of the New York Supreme Court determining Appellant Jeffrey E. Epstein to be a Level 3 sex offender, without designation, should be vacated, and Appellant's SORA level should be recalculated -- either by this Court based on the present record or upon remand to a different Justice in the lower court -

arance. Enclosed please find a copy of the Board of Examiners recommendation. '.ry trt,y you, . Mary A. Price. CCS Supreme Court - Criminal Term New York County EFTA00231517 Offender Name: JEFFREY E EPSTEIN NYSID ft: O51909 1ST Reviewer Initials: lie following is the Board of Examiners of Sex Offender

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving 2 EFTA00231549 women who were seventee

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

ace New York, NYilli m Telephone: 5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County. 6. THENATURE AND OBJECTOF THE CAUSE OF-ACTION OR SPECIAL PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the

y in its response to hearing the District Attorney disavow the reliability of the Board's recommendation, in receiving the arguments of counsel for Appellant, and in rendering its Order as a whole. First, although the SORA statute clearly contemplates that the District Attorney may depart from the Board'

many SORAs much less troubling than this one where the People would never make a downward departure like this.16 A.84:21-85:10 (Tr.). Later, when Appellant's counsel disputed that there were any credible -- much less prosecuted -- allegations that Appellant ever used force, the Court again began compar

his appearance. Enclosed please find a copy or the Board of Ixaminers recommendation. t.aiy Mary A. Price. CC'S Supreme Court - Criminal 'Fenn New York County enc. EFTA00232637 Offender Name: JEFFREY E EPSTEIN NYS1D OS 1909 1ST Reviewer Initials: le following is the Board of Examiners of Sex Offend

to Procuring a Person Under 18 for Prostitution, Fla. Stat. § 796.03, and Felony Solicitation of Prostitution, Fla. Stat. § 796.07(2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA heari

nreliable, based on allegations that were determined to be not prosecutable, and not provable by clear and convincing evidence? 3. In calculating Appellant's risk level under SORA, may the Court score points for consensual prostitution-related conduct involving EFTA00232669 women who were seventeen y