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t, 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 September 24, 2007 — Mr. Epstein paid $100,000 to "a company founded and run by
report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecutio
n. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward modificati
, 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
Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assis- tant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to re- 319 view and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward mo
t, 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 September 24, 2007 — Mr. Epstein paid $100,000 to "a company founded and run by
report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecutio
n. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward modificati
, 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
Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assis- tant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to re- 319 view and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward mo
report in the Miami Herald (authored by Julie K. Brown) relating to Mr. Epstein's Florida Non-Prosecutio
t, 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 September 24, 2007 — Mr. Epstein paid $100,000 to "a company founded and run by
n. Indict. # 30129/2010, (N.Y. Sup. Ct.), SORA Hearing Transcript, dated Jan. 18, 2011. At the hearing, New York County Assistant District Attorney Jennifer Gaffney joined in Defense Counsel's appeal to review and overturn the decision of the Board of Examiners of Sex Offenders and achieve a downward modificati
A00805349 TABLE OF AUTHORITIES Page(s) Cases Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165
pleading guilty to solicitation of a single minor. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. Remarkably, New York Assistant District Attorney Jennifer Gaffney ignored the NYBSO recommendation and asked the trial court tasked with deciding Epstein's sex-offender status to designate him as a level one offen
KMBT_C654e-20190114185410
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
Page: HOUSE_OVERSIGHT_016424 →1 legal hearing, asking a judge to cut the filthy- rich felon a break on the severity of his sex- offender status, according to court documents. ADA Jennifer Gaffney supported a request by Epstein — who allegedly peddled $15,000-a-night teen “sex slaves” to rich men like Britain’s Prince Andrew — that he only be l
Page: HOUSE_OVERSIGHT_016460 →Entities connected to both Julie K. Brown and Jennifer Gaffney

Jeffrey Epstein
PERSON
George W. Bush
PERSONDarren Indyke
PERSONLeon Black
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bill Clinton
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATION
Stephen Hawking
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Joe Biden
PERSON
Michael Jackson
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Richard Kahn
PERSON