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terprise 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, 448 U.S. 555 (1980) 12, 13 Constitutions U.S. Const. amend. I 11 N.Y. State Const. art. I. § 8 11 Statutes N.Y. Civ. Rights Law § 50-b N.Y
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
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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
n of New Circuit Executive. 26 NYPD Arrests West Virginia Man Over Subway Bomb Scare. 27 Daniel Pantaleo O
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,"
n of New Circuit Executive. 26 NYPD Arrests West Virginia Man Over Subway Bomb Scare. 27 Daniel Pantaleo O
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,"
KMBT_C654e-20190114185410
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
Page: HOUSE_OVERSIGHT_016420 →et and, at one point, owned a Boeing 727. HOUSE_OVERSIGHT_016444 --- PAGE BREAK --- HOUSE_OVERSIGHT_016445 --- PAGE BREAK --- e = sad Si, = a E Virginia Roberts says she was used as a sex slave for Jeffrey Epstein for years starting at the age of 16. Roberts says that Epstein also lent her out to some of his
Page: HOUSE_OVERSIGHT_016446 →45 --- PAGE BREAK --- e = sad Si, = a E Virginia Roberts says she was used as a sex slave for Jeffrey Epstein for years starting at the age of 16. Roberts says that Epstein also lent her out to some of his wealthy, powerful acquaintances for sex. COURTESY OF VIRGINIA ROBERTS He has never been in the Fo
Page: HOUSE_OVERSIGHT_016446 →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
Page: HOUSE_OVERSIGHT_016460 →Entities connected to both Virginia Giuffre and Ruth Pickholz

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
New York
LOCATIONJane Doe
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSONthe Southern District
LOCATION
Marc Rich
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSONFBI
ORGANIZATION