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

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

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

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

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

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

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

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

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

to the New York State Appellate Division and was unanimously upheld. I read this morning a copy of the transcript of the proceedings before Judge Pickholz which I'm likely to place on the docket after today's session. And the question is for each side. First of all, they're free to comment on my descr

he Board of Examiners of Sex Offenders New York state and then in state court by the courts and, particularly, a decision of the Honorable Justice Ruth Pickholz on our about January 18, 2011. I believe that decision was appealed to the New York State Appellate Division and was unanimously upheld. I read th

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

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

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

to the New York State Appellate Division and was unanimously upheld. I read this morning a copy of the transcript of the proceedings before Judge Pickholz which I'm likely to place on the docket after today's session. And the question is for each side. First of all, they're free to comment on my descr

he Board of Examiners of Sex Offenders New York state and then in state court by the courts and, particularly, a decision of the Honorable Justice Ruth Pickholz on our about January 18, 2011. I believe that decision was appealed to the New York State Appellate Division and was unanimously upheld. I read th

Defendant-Appellant. BRIEF FOR RESPONDENT INTRODUCTION Defendant, Jeffrey Epstein, appeals from an order of the Supreme Court, New York County (Ruth Pickholz, J.), entered on January 18, 2011, adjudicating him a level-three sex offender pursuant to the Sex Offender Registration Act ("SORA"). By the under

ere was none. For those reasons, the Board recommended that defendant be designated a level-three sex offender. At the SORA hearing before Justice Pickholz, defendant essentially took the position that the level-three designation could not be supported by the crimes with which he had actually been char

lm Beach Sheriffs Office Booking Card for Jeffrey Epstein, dated June 30, 2008 A47 EFTA00181235 UI PAGE Letter from Jay P. Leflcowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

The Honorable Ruth Pickholz New York County Supreme Court Part 66 It 1 Centre Street New York, NY 10013 Re: SCID No. 30129-2010 Dear Justice Pickholz: I ant writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30>a.m. on Wednesda

2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA hearing). Appellant seeks to vacate the Order because the Court's risk level determination was not supported by clear and convincing ev

V. SORA Hearing On January 18, 2011, a SORA hearing was conducted in New York Supreme Court, Criminal Term, New York County, Part 66 before Hon. Ruth Pickholz. See A.81 (Handwritten Notations on Court Jacket); A.82 (Tr. generally). At the hearing, the People made a record that based on their investigatio

Defendant-Appellant. BRIEF FOR RESPONDENT INTRODUCTION Defendant, Jeffrey Epstein, appeals from an order of the Supreme Court, New York County (Ruth Pickholz, J.), entered on January 18, 2011, adjudicating him a level-three sex offender pursuant to the Sex Offender Registration Act ("SORA"). By the under

ere was none. For those reasons, the Board recommended that defendant be designated a level-three sex offender. At the SORA hearing before Justice Pickholz, defendant essentially took the position that the level-three designation could not be supported by the crimes with which he had actually been char

upreme Court Part 66 III Centre Street New York, NY 10013 FacsrmM www.lOrklang com September 7, 2010 / Re: SCID No. 30129-2010 Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30 a.m. on Wednesday

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00792402 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

ere was none. For those reasons, the Board recommended that defendant be designated a level-three sex offender. At the SORA hearing before Justice Pickholz, defendant essentially took the position that the level-three designation could not be supported by the crimes with which he had actually been char

Defendant-Appellant. BRIEF FOR RESPONDENT INTRODUCTION Defendant, Jeffrey Epstein, appeals from an order of the Supreme Court, New York County (Ruth Pickholz, J.), entered on January 18, 2011, adjudicating him a level-three sex offender pursuant to the Sex Offender Registration Act ("SORA"). By the under

ickholz New York County Supreme Court Part 66 111 Centre Street New York, NY 10013 September 7, 2010 1. Re: $CID No. 30129-2010 Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:30a.m. on Wednesday,

er or the same as the one recommended by the Board of Examiners. Your hearing has been scheduled for September 15,2010 at 9:30 a.m.. before the Hon. Ruth Pickholz in part 66 located at 111 Centre Street. New York, N.Y. You have a right to attend this hearing. I fyou wish to waive your appearance tin• the hear

V. SORA Hearing On January 18, 2011, a SORA hearing was conducted in New York Supreme Court, Criminal Term, New York County, Part 66 before Hon. Ruth Pickholz. See A.81 (Handwritten Notations on Court Jacket); A.82 (Tr. generally). At the hearing, the People made a record that based on their investigatio

2)(f), for which Appellant was sentenced to consecutive terms of 12 months and 6 months incarceration, followed by 12 months of Community Control. (Pickholz, J. at SORA hearing). Appellant seeks to vacate the Order because the Court's risk level determination was not supported by clear and convincing ev

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

of SORA Level Determination Hearing (with attachment), dated August 26, 2010 A71 EFTA00180924 iii PAGE Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a Continuance of the Hearing, dated September 9, 2010 A77 Letter from Supreme Court to Sex Offender Registry Unit Enclosing Final Det

The Honorable Ruth Pickholz New York County Supreme Court Part 66 Ill Centre Street New York, NY 10013 Re: SCID No. 30129-2010' Dear Justice Pickholz: I am writing regarding the hearing for Mr. Jeffrey Epstein in the above-referenced matter, which is currently scheduled for 9:304.m. on Wednesday,