Epstein Secrets

e M. Clemente of Greenberg Traurig, LLP, New York, New York, for appellant. Nina D. Boyajian of Greenberg Traurig, LLP, Los Angeles, California, Pro Hac Vice, for appellant. Michael J. Grygiel of Greenberg Traurig, LLP, Albany, New York, Pro Hac Vice, for appellant. Collin Doern Jackson, Jennifer Fl

close grand jury materials despite the traditional rule of secrecy. In fact, this is contemplated and supported by section 905.27’s language. Craig also provides helpful instruction on what a trial court should consider when faced with this issue. NOT A CERTIFIED COPY 5 Mindful that ther

gs who might be affected by disclosure are still alive; and (ix) the additional need for maintaining secrecy in the particular case in question. Craig, 131 F. 3d at 106. With this foundation, we begin our analysis of section 905.27. That statute’s pertinent subsections provide: (1) A grand j

da Bar No. 849324 [email protected] [email protected] [email protected] -and- By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 [email protected] By: /s/ Nina D. Boyajian

pite many attempts over several months to force itself to reach an opposite conclusion; however, after weighing all of the factors In re Petition of Craig, 131 F.3d 99, it is clear there is no nexus between those findings and furthering justice. This Court cannot weigh those factors in a way that “wil

AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN OPPOSITION TO PROPOSED REMEDIES Bradley J. Edwards Edwards Pottin er LP Paul G. Cassell Pro Hac Vice This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsemen

terpreting plea agreements. Indeed, numerous cases hold that such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig v. People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the mandatory parole period); State v. Garcia, 582