This document is a legal brief filed by Jeffrey E. Epstein's attorneys, Jay P. Lefkowitz and Sandra Lynn Musumeci of Kirkland & Ellis LLP, in the New York Supreme Court, Appellate Division-First Department. The brief argues against the court's determination of Epstein as a Level 3 sex offender under New York's Sexual Offender Registration Act (SORA). The brief contends that the court's decision was not supported by clear and convincing evidence, was based on improper considerations, and violated Epstein's due process rights. The brief requests the appellate court to vacate the lower court's order and recalculate Epstein's risk level based solely on evidence proven by clear and convincing evidence.
documents/EFTA00181023.pdf
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