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, by wholeheartedly relying upon -- and even quoting in exacting and lurid detail -- the very Probable Cause Affidavit that was rejected by the Florida prosecutors who handled Appellant's criminal case and which the People themselves expressly repudiated as unreliable for purposes of calculating Appellant's risk level under SORA. Whether this complete abandonment of the People's previous position and sudden defense of the hearing court's unsupportable Order reflects a sincere but misguided re-evaluation of the facts at issue or a more opportunistic surrender to political pressures to avoid a potentially unpopular position on a sex crimes case, the People should be estopped from so radically reversing course on appeal. In direct and reasonable reliance on the People's representations that the District 1 EFTA01085764