This document is a legal brief submitted by the defense for Jeffrey E. Epstein in an appeal against a Level 3 sex offender designation under New York's Sexual Offender Registration Act (SORA). The brief argues that the court's determination was not supported by clear and convincing evidence, relied on improper considerations, and violated Epstein's due process rights. The defense contends that the court improperly adopted the Board's recommendation without sufficient evidence and failed to provide a fair hearing. The brief seeks to vacate the Level 3 determination and requests a recalculation of Epstein's risk level based on evidence that can be proven by clear and convincing evidence.
documents/EFTA01077101.pdf
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