Epstein Secrets

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

he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki

ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl

, 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

decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attor- ney application, stating: "I am just a little overwhelmed that the People are m

llowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hear- ing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. See Peopl

, 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

decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attor- ney application, stating: "I am just a little overwhelmed that the People are m

llowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hear- ing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. See Peopl

A00805349 TABLE OF AUTHORITIES Page(s) Cases Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165

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

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

ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl

he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki

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

ve allowed Mr. Epstein to avoid his reporting obligations. In a Scx Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl

the decision of the Board of Examiners of Scx Offenders and achieve a downward modification of Mr. Epstein's sex offender status. j at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki

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

he decision of the Board of Examiners of Sex Offenders and achieve a downward modification of Mr. Epstein's sex offender status. Id. at 2-15. Judge Pickholz appeared to be stunned by the joint Defense Counsel/District Attorney application, stating: "I am just a little overwhelmed that the People are maki

ve allowed Mr. Epstein to avoid his reporting obligations. In a Sex Offender Registration Act Hearing on January 11, 2018, held before the Honorable Ruth Pickholz, Mr. Epstein's application was (firmly) denied, principally because it had been established by the Board of Examiners of Sex Offenders. ice. Peopl

om, 249 2d 891 (4th Dep't 1998) '30 People u. Brown, 7 M.3d 831 (3d Dep't 2004) 11, 18, 25, 30 Peo

counsel and sought a brief adjournment to provide counsel an opportunity to prepare for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 7, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorney assigned to the SORA

scribed procedures. 26 EFTA00798146 People v. Brown, 7 A.D.3d 831, 833 (3d Dep't 2004) (rejecting Boa

counsel and sought a brief adjournment to provide counsel an opportunity to prepare for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorney assigned to the SOR

sis for scoring under SORA. See, e.g., People u. Brown, 7 M.3d 831, 832-33 (3d Dep't 2004) (overturning

ounsel and sought a brief adjournment to provide counsel an opportunity to prepare for the hearing. See A.77 (Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz, dated Sept. 9, 2010). In October 2010, Appellant's counsel submitted a detailed memorandum to the Assistant District Attorney assigned to the SORA