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¶
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TITLE OF ACTION: As set forth in caption.
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FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES: As set forth in caption. There has been no change in the parties.
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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:¶
- 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:¶
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COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL IS TAKEN: New York Supreme Court (Criminal Term), New York County.
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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.
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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.
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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