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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
orities 22 NYCRR § 1250.1(e)(3) 1, 9, 11 iii 481 I-3721-9459v 2 3930033-000039 EFTA00805351 Non-party movant NYP Holdings, Inc., publisher of the New York Post (the "Post"), respectfully submits this memorandum of law in support of its motion, filed pursuant to 22 NYCRR § 1250.1(eX3), for an order unsealin
he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki
ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl
9 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted. Mr. Epstein has never reported as a sex offender to New York law enforcement. See July 10, 2019 NY Post Article. "The NYPD cop assigned t
decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attor- ney application, stating: "I am just a little overwhelmed that the People are m
llowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hear- ing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. See Peopl
A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted, Mr. Epstein has never reported as a sex offender to New York law enforcement See July 10, 2019 NY Post Article. "The NYPD cop assigned
decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attor- ney application, stating: "I am just a little overwhelmed that the People are m
llowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hear- ing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. See Peopl
A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted, Mr. Epstein has never reported as a sex offender to New York law enforcement See July 10, 2019 NY Post Article. "The NYPD cop assigned
ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl
he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki
9 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted. Mr. Epstein has never reported as a sex offender to New York law enforcement. See July 10, 2019 NY Post Article. "The NYPD cop assigned t
ve allowed Mr. Epstein to avoid his reporting obligations. In a Scx Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl
the decision of the Board of Examiners of Scx Offenders and achieve a downward modification of Mr. Epstein's sex offender status. j at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki
9 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted. Mr. Epstein has never reported as a sex offender to New York law enforcement. See July 10, 2019 NY Post Article. "The NYPD cop assigned t
he Board of Examiners of Sex Offenders New York state and then in state court by the courts and, particularly, a decision of the Honorable Justice Ruth Pickholz on our about January 18, 2011. I believe that decision was appealed to the New York State Appellate Division and was unanimously upheld. I read th
to the New York State Appellate Division and was unanimously upheld. I read this morning a copy of the transcript of the proceedings before Judge Pickholz which I'm likely to place on the docket after today's session. And the question is for each side. First of all, they're free to comment on my descr
questions of this morning. THE COURT: That would be helpful. There are two things. One is another disclosure on my part. I did happen to read in the New York Post a story about the New York state sex offender registration. The thrust of that story was that Mr. Epstein -- or at least it appeared to me to be t
he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki
ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl
9 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's order, according to a July 10, 2019 investigative report by the New York Post, as noted. Mr. Epstein has never reported as a sex offender to New York law enforcement. See July 10, 2019 NY Post Article. "The NYPD cop assigned t
to the New York State Appellate Division and was unanimously upheld. I read this morning a copy of the transcript of the proceedings before Judge Pickholz which I'm likely to place on the docket after today's session. And the question is for each side. First of all, they're free to comment on my descr
he Board of Examiners of Sex Offenders New York state and then in state court by the courts and, particularly, a decision of the Honorable Justice Ruth Pickholz on our about January 18, 2011. I believe that decision was appealed to the New York State Appellate Division and was unanimously upheld. I read th
questions of this morning. THE COURT: That would be helpful. There are two things. One is another disclosure on my part. I did happen to read in the New York Post a story about the New York state sex offender registration. The thrust of that story was that Mr. Epstein -- or at least it appeared to me to be t
Entities connected to both Ruth Pickholz and The New York Post

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Joe Biden
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Prince Andrew
PERSON
Department of Justice
ORGANIZATIONLeon Black
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Julie K. Brown
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Virginia Giuffre
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New York
LOCATION
Bill Clinton
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Michael Jackson
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Ghislaine Maxwell
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United States
LOCATION
Scarlett Johansson
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George W. Bush
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Stephen Hawking
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George Mitchell
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Eric Trump
PERSONEmmy Taylor
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Michael Cohen
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