INTRODUCTION In a stunning reversal of the position they espoused on the record at the SORA hearing, the People oppose Appellant Jeffrey E. Epstein's appeal of the Order of the New York Supreme Court, Criminal Term, New York County, determining him to be a Level 3 sex offender, without designation, under New York's Sexual Offender Registration Act (SORA), Correction Law Article 6-C. Remarkably, the People seek to validate their newly-adopted position on appeal by wholeheartedly relying upon -- and even quoting in exacting and lurid detail -- the very Probable Cause Affidavit that the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA and that was rejected by the Florida prosecutors who handled Appellant's criminal case. Whether this complete abandonment of the People's previous stance and sudden defense of the hearing court's unsupportable Order reflects an opportunistic surrender to political pressures to avoid a potentially unpopular position on a sex crimes case or some other equally unwarranted re-evaluation, the People should be estopped from so radically reversing course on appeal. The District Attorney's Office 1 EFTA01085680