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RK, • 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 Robert D. Balin John M.
iction for Sex Crimes and Designation as a Level Three Sex Offender 3 B. Media Interest in New York and Florida Prosecutors' Lenient Handling of Epstein's Case 5 C. The Post's Efforts to Obtain the Appellate Briefing Filed with the First Department 8 ARGUMENT 9 I. THE POST HAS THE RIGHT TO M
had never spoken to the federal investigators in Florida who had reached the conclusion that Epstein was a serial abuser of underage girls. Id Ex. C. Epstein subsequently commenced this Appeal, seeking to overturn the trial court's ruling that he is a level three sex offender. The appellate briefs submitt
Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM
Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM O
008), available at https://nypost.com/2008/06/30/jeffrey-epstein-pleads-guilty-to-prostitution-chargest Mother se
n on the disclosure of the appellate briefs. Id. Mr. Epstein's lawyer stated that he would not take a positio
(2d Cir. 1980) 11, 13 In re Associated Press v. Bell, 70 N.Y.2d 32, 517 N.Y.S.2d 444 (1987) 11 In re Capital Newspapers Div. of Hearst Corp. v. Moynihan, 125 A.D.2d 34, 512 N.Y.S.2d 266 (3d Dep't 1987), aff'd on other grounds, 71 N.Y.2d 263, 525 N.Y.S.2d 24 (1988) 9 In re Herald Co. v. Weisenberg,
y in the Epstein Claims Resolution Program, yet a stay also would permit her the opportunity to do so. She is inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay. While Plaintiff's counsel refuses to state whether his client is one of the three accusers in
Page: EFTA00026735 →Denver, Colorado 80203 PH 303.831.7364 FR 303.832.2628 August 19, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K.
Page: EFTA00026735 →an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's s
Page: EFTA00026736 →esting a stay of discovery as to her, based on the U.S. Attorney's Office's public proclamation of an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's stated intent to participate in the Voluntary Claims Resolution Program in the U.S. Virgin Islands. v. Indy
Page: EFTA00026736 →for each of the other pending actions concerning Mr. Epstein and the one other concerning Ms. Maxwell, requir
Page: EFTA00026738 →) Civil Action No. 15-CV-07433-RWS Ghlslaine Maxwell Defendant ) ) SUBPOENA TO APPEAR AND TESTIFY AT A HEARINC OR TRIAL. IN A CIVIL ACTION To: JEFFREY E•STEIN 9 East 71st •treet, New York, NY10021 043IPM of person to wham this subpoena is directed/ YOU A E COMMANDED to appear in the United States district c
FY AT A HEARINC OR TRIAL. IN A CIVIL ACTION To: JEFFREY E•STEIN 9 East 71st •treet, New York, NY10021 043
in this civil action. When you arrive, you must remain at the court until the judge or a court officer allows yo to leave. .• Place: Daniel P ck Moynihan Unied St tes Courthouse 500 Pea Street, New York, NY 1 0007-1 31 2 Courtroom No.: 19C Date and Tune: 03/13/2017 9:00 am You mu also bring with y
1/20, Erickson, Jackson, Morgan), the New York Times (11/20, Bolton), the Washington Post (11/20, Alemany, Goodwin, et al.) (2) (3), the BBC (11/20, Epstein), CNN (11/20, Ferris, Raju, Grayer) (2), Fox News (11/20, Elkind, Olson) (2), ABC News (11/20, Pecorin, Cherner, et al.), NBC News (11/20, Wong, St
on (11/20, Stevens) also reported on the story. Man Who Bought a Gun to 'Shoot Up a Synagogue' is Sentenced to 10 Years The New York Times (11/20, Moynihan) reported that Christopher Brown, a 21-year-old man, was sentenced to 10 years in prison after pleading guilty to possessing a weapon as a crime of
KMBT_C654e-20190114185410
, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOT
Page: HOUSE_OVERSIGHT_016420 →, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOTI
Page: HOUSE_OVERSIGHT_016420 →written by Rebecca Rosenberg and Danika Fears, which was published by the Post on January 7, 2015, entitled “DA’s office ‘went easy’ on sex offender Epstein.” 4840-5788-8644v. 1 3930033 -000039 HOUSE_OVERSIGHT_016424 --- PAGE BREAK --- os Annexed hereto as Exhibit C is a true and correct copy of an ar
Page: HOUSE_OVERSIGHT_016425 →ement about sexual assault — and a decade before the fall of Harvey Weinstein, Bill Cosby and U.S. Olympic gymnastics doctor Larry Nassar — there was Jeffrey Edward Epstein. Epstein, a multimillionaire hedge fund manager whose friends included a constellation of entertainers, politicians, business titans and royalty, fo
Page: HOUSE_OVERSIGHT_016432 →Entities connected to both Jeffrey Epstein and Moynihan

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Condoleezza Rice
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSON
New York
LOCATION
New York City
LOCATION
U.S. Virgin Islands
LOCATION
Virginia Giuffre
PERSON
Ken Starr
PERSON
Harvey Weinstein
PERSON