Epstein Secrets

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

d Dep't 1993) 11, 14 People v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d 239 (1st Dep't 2011) passim 4811.3721.9459v.2 3930033-000039 EFTA00805350 Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984) Press-Enterprise Co. v. Superior Court, 478 U.S. 1 (1986) 13 11 Richmond Newspaper& Inc. v. Virginia, 4

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general public. Press-Enterprise Co. v. Superior Court, 478 U.S. 1, 8, 106 S. Ct. 2735 (1986) ("Press-Enterprise If'). Second, courts must consider "whether public access plays a signi

likely relevant to its pending Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended C

Virgin Islands Criminally Influenced and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed Feb

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities

"CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities b

F.3d 83, 92 (2d Cir. 2004). First, courts must consider "whether the place and process have historically been open to the press and general public. Press-Enterprise Co. v. Superior Court, 478 U.S. 1, 8, 106 S. Ct. 2735 (1986) ("Press-Enterprise If'). Second, courts must consider "whether public access plays a signi

. CRIM. P. 6(e) AND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the

ND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the grand jury

their Statement of Undisputed Facts allege that Jeffrey Epstein ("Epstein") and others have committed cri

s to the sealed documents and transcripts here could easily kill many reputations. This overriding interest is, I believe, of a higher value under [Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude di

R. CRIM. P. 6(e) AND/OR CONSTITUTIONAL MANDATES. Several of the "facts" that Petitioners include in their Statement of Undisputed Facts allege that Epstein and others have committed crimes for which they were never charged or convicted. Others refer to matters that were occurring before the grand jury.

to the sealed documents and transcripts here could easily kill many re utations. This overriding interest is, I believe, of a higher value under [ Press-Enterprise Co. I Superior Court , 464 U.S. 501 (1984)] so as to warrant sealing, and provides good cause under the common-law access balancing test to preclude di

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOT

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOTI

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

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

, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Int

British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involv

described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young females for sexual activity with Jeffrey Epstein ("Epstein"), that she, M, had been interviewed by the Federal Bureau of Investigation ("FBI") in 2011, and that she had discussed Maxwell's involvement in t

ppression `is essential to preserve higher values and is narrowly tailored to serve that interest.' " Hartford Courant Co., 380 F.3d at 96 (quoting Press-Enterprise Co. v. Superior Court of Cal., Riverside Cnty., 464 U.S. 501, 510, 104 S.Ct. 819, 78 L.Ed.2d 629 (1984) ) (internal citation omitted). What must be dete

xwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also specifically asserts her right to an open and public trial pursuant to the Sixth Amendment. Press-Enterprise Co. v. Superior Court (Press-Enterprise II), 478 U.S. 1, 7 (1986). Objections to Redactions Proposed on Pages 1-128 The government's proposed redactio

tion for why Ms. Maxwell is not mentioned once in this diary: Accuser-2 "stopped writing in her journal about a month after that first meeting with Epstein" and the rest of her diary is "personal in nature and ha[s] nothing to do with the defendant or Epstein." How that document, or its origin, incompl