EFTA00181236

# A1
Appellant's Pre-Argument Statement, dated February 9, 2011
[pp. A1-A2]

## SUPREME COURT FOR THE STATE OF NEW YORK COUNTY OF NEW YORK

PEOPLE OF THE STATE OF NEW YORK,

Plaintiff-Respondent,

Index No.: 30129-2010

- against -

JEFFREY E. EPSTEIN,

Defendant-Appellant.

PRE-ARGUMENT STATEMENT

1. TITLE OF ACTION: As set forth in caption.

2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties.

3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT OR PETITIONER:

Jay P. Lefkowitz, P.C.

Sandra Lynn Musumeci

KIRKLAND & ELLIS LLP

601 Lexington Avenue

New York, New York 10022-4611

Telephone:

Facsimile:

4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR RESPONDENT:

Cyrus R. Vance, Jr.

NEW YORK DISTRICT ATTORNEY'S OFFICE

One Hogan Place

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 the Correction Law.

7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW: Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual offender, without additional designation.

8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of