This is a reply brief filed by Jay P. Lefkowitz and Sandra Lynn Musumeci of Kirkland & Ellis LLP on behalf of Jeffrey E. Epstein, the defendant-appellant, in the New York Supreme Court, Appellate Division-First Department. The brief argues against the New York Supreme Court's determination of Epstein as a Level 3 sex offender under the Sexual Offender Registration Act (SORA). The brief contends that the court's decision was based on unreliable materials and not supported by clear and convincing evidence, as required by SORA and federal constitutional law. It also argues that the court's decision was based on improper considerations and violated Epstein's statutory and constitutional rights.
documents/EFTA01168858.pdf
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