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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00727403

21 pages
Pages 21–21 / 21
Page 21 / 21
KIRKLAND & ELLIS LLP 
In short, designating Jeffrey-Mr. Epstein with Level 1 SORA designation will provide the 
People of New York with full and adequate protection against the virtually non-existent risk of 
reoffense that Jeffrey Epstein poses, particularly given the limited sheri-amount of time that Mr. 
Epstein spends in the city and in the state. To require him to comply with any more stringent 
demands under SORA would needlessly duplicate -- and indeed, unnecessarily go well beyond --
the efforts of jurisdictions having much greater contact with and control over Jeffrer
.
 Mr. 
Epstein. In addition, designating Jeffrey  Mr. Epstein as a Level 3 offender would require him to 
return to New York to re-register every 90 days, even if he might not otherwise plan to be in the 
state, thereby causing him actually to spend more time in New York than he ordinarily would. 
Moreover, designating Jeffrey  Mr. Epstein as anything other than a Level 1 offender would 
squander the city and state's resources -- resources that could be more effectively used 
monitoring dangerous, high-risk sex offenders who are in fact full-time New York residents -- to 
contain a risk of reoffense that Mr. Epstein does not present. 
Imposing the more severe reporting requirements of a higher sex offender risk 
designation upon JeffrerMr. Epstein would not serve the ends of justice and the protective -- not 
punitive -- goals which SORA is intended to promote. Accordingly, we respectfully ask you to 
follow the lead of the other jurisdictions that have already evaluated Mr. Epstein's offenses --
and all adjudged him to be the lowest level of registrant -- by consenting to designate Jeffrey-Mr. 
Epstein with the appropriate SORA classification of Level 1. 
21 
K&E 17760332.3 
EFTA00727423
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