Epstein Secrets

E OF NEW • YORK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP

ts and designated Epstein as a level three sex offender. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. At a hearing preceding her ruling, Justice Pickholz told the Assistant District Attorney that she had "never seen the 3 4811-3721-9459v.2 3930°33-000039 EFTA00805354 prosecutor's office do anythin

because "there are no real victims here." Id. Ex. C. In January 2011, the judge presiding over the sex-offender registration proceedings, Justice Ruth Pickholz, rejected ADA Gaffney's arguments and designated Epstein as a level three sex offender. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. At a hearing

ich is the least-restrictive category possible and is typically applied to offenders who pose the lowest risk of committing further crimes. Id. ADA Gaffney argued that, since "there was only an indictment for one victim," Epstein should not be placed under the heavy scrutiny required for the most danger

went forward on only one count of soliciting a minor. Gaffney said the victims, although they spoke to police early on, did not cooperate. Judge Ruth Pickholz would have none of it. "I have to tell you, I am a little overwhelmed because I have never seen a prosecutor's office do anything like this," Pick

holz would have none of it. "I have to tell you, I am a little overwhelmed because I have never seen a prosecutor's office do anything like this," Pickholz said. "I have done many SORAs much less troubling than this one where the [prosecutor] would never make a downward argument like this." Gaffney sa

tant District Attorney Jennifer Gaffney. Yet, the New York State Board of Examiners of Sex Offenders recommended Epstein be designated a Level 3. Gaffney said she was unable to rely on the Palm Beach Police's probable EFTA01482075 cause affidavit -- which listed multiple victims and multiple charge

earing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, according to a transcript of the hearing. Ms. Gaffney agreed that it was "incredibly unusual for us to make a downward argument,"

torney who oversaw the Epstein case in Florida would come speak to them about his investigation, Ms. Musumeci wrote in a Dec. 10, 2010, email to Ms. Gaffney and Mr. Egan in the Manhattan district attorney's office. The Manhattan prosecutors declined the offer, but they contacted then-current officials a

earing in New York Supreme Court. "I am a little overwhelmed because I have never seen the prosecutor's office do anything like this," Justice Ruth Pickholz told Ms. Gaffney, according to a transcript of the hearing. Ms. Gaffney agreed that it was "incredibly unusual for us to make a downward argument,"

torney who oversaw the Epstein case in Florida would come speak to them about his investigation, Ms. Musumeci wrote in a Dec. 10, 2010, email to Ms. Gaffney and Mr. Egan in the Manhattan district attorney's office. The Manhattan prosecutors declined the offer, but they contacted then-current officials a

THE STATE OF NEW YORK, : App. Div. No. 6081 Respondent, ; On Appeal from New York Supreme Court, : New York County, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOTION BY NYP HOLDINGS, INC. TQ UNSEAL APPELLATE BRIEFS PLEASE TAKE NOTICE that, upon t

ister as Level 3 — which would require he travel to New York every 90 days and check in with cops. HOUSE_OVERSIGHT_016459 --- PAGE BREAK --- Judge Ruth Pickholz was flabbergasted. She couldn’t understand why the DA would want to go easy on Epstein, after the New York State Board of Examiners of Sex Offenders

vel 1. The judge was stunned. “| have never seen the prosecutor’s office do anything like this,” Manhattan Supreme Court Justice Ruth Pickholz toid Gaffney. “| have done many [cases] much less troubling than this one where [prosecutors] would never make a downward argument like this.” Pressed by the jud