Epstein Secrets

, on November 28, 2018 and on December 3, 2018 - very soon after the publication of a 3-part investigative report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecution Agreement dated Sep- tember 24, 2007 - Mr. Epstein paid $100,000 to "a company founded and run

eport in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecuti

every 90 days." Id. Epstein appealed but Judge Pickholz's decision was unanimously af- firmed, on November 17, 2011, by a panel of five judges of the Appellate Division of the New York State Supreme Court. Peo- ple v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's

, on November 28, 2018 and on December 3, 2018 - very soon after the publication of a 3-part investigative report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecution Agreement dated Sep- tember 24, 2007 - Mr. Epstein paid $100,000 to "a company founded and run

eport in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecuti

every 90 days." Id. Epstein appealed but Judge Pickholz's decision was unanimously af- firmed, on November 17, 2011, by a panel of five judges of the Appellate Division of the New York State Supreme Court. Peo- ple v. Epstein, 89 A.D.3d 570, 933 N.Y.S.2d 239 (N.Y. App. Div. 2011). Notwithstanding Judge Pickholz's

nvestigation of U.S. Secretary of Commerce Ronald Brown; the U.S. Attorney's Office for the Eastern Dist

Attorney's Office for the Eastern District of Virginia; and the U.S. Attorney's Office of the District of Maryland, where he served as the Chief of the Appellate Division. After leaving federal service, Mr. Biran served as the named partner in his own firm, Biran Kelly, before joining Baker Donelson as a partner. 5

of an opportunity to engage in prohibited conduct. See, e.g,. United States v. Sanchez-Berrios, 424 F.3d 65, 76-77 (1" Cir. 2005); United States v. Brown, 43 F.3d 618, 625 (I1th Cu. 1995). The government cannot fairly, or consistent with the rule of lenity, advocate a broader definition of the same te

ttorney representative." She had proposed local products-liability lawyer, Humberto Ocariz and claimed he had been recommended by a "good friend in the Appellate Division." account was misleading, as it omitted that this "good friend" was ha live-in boyfriend, and that Mr. Ocariz was his former law-school roommate.

are relevant to this motion, of which I have personal knowledge. 3. Annexed hereto as Exhibit A is a true and correct copy of an article written by Julie K. Brown and published by the Miami Herald on November 28, 2018, entitled “Cops worked to put serial sex abuser in prison. Prosecutors worked to cut him a bre

le documents under seal. This is not particular to People v. Epstein; it is routine across our appellate filings. My understanding is that it is also the Appellate Division’s (the court's) practice to maintain such seal. That being said, | have discussed your second question with our attorneys. If the Post petitions the c