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1.6 MB

Extraction Summary

2
People
4
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal brief / motion to unseal (page 12)
File Size: 1.6 MB
Summary

This document is page 12 of a legal brief filed by 'The Post' (likely the NY Post) arguing for the unsealing of appellate briefs related to Jeffrey Epstein. The text argues that there is 'good cause' to unseal these documents to help the public understand why the Manhattan District Attorney's Office initially argued for Epstein to be registered only as a level one sex offender, suggesting 'undue deference' to a 'dangerous pedophile.' The document bears a House Oversight Committee Bates stamp.

People (2)

Name Role Context
Jeffrey Epstein Subject of legal proceedings
Described as a "dangerous pedophile, who is unusually rich and well-connected" and a sex offender.
Manhattan District Attorney Public Official/Office
Accused of potentially showing "undue deference" to Epstein.

Organizations (4)

Name Type Context
The Post
Movant requesting the unsealing of documents (likely The New York Post).
Office of the Manhattan District Attorney
Prosecutorial body whose actions regarding Epstein are being scrutinized.
Daily News, L.P.
Cited in case law precedent.
House Oversight Committee
Implied by Bates stamp 'HOUSE_OVERSIGHT'.

Timeline (2 events)

Unknown (Current proceeding)
The Post's motion to unseal appellate briefs.
New York Court
The Post The Court
Unknown (Historical context)
Manhattan DA argued Epstein should be a level one sex offender before changing position on appeal.
New York Courts

Locations (2)

Location Context
Jurisdiction of the court and District Attorney (implied by N.Y. citations and context).
Jurisdiction of the District Attorney.

Relationships (2)

Manhattan District Attorney Legal/Prosecutorial Jeffrey Epstein
Text questions if the DA showed 'undue deference' to Epstein regarding his sex offender registration level.
The Post Adversarial/Investigative Manhattan District Attorney
The Post is seeking unsealed briefs to scrutinize the DA's conduct.

Key Quotes (3)

"initially showed undue deference to a dangerous pedophile, who is unusually rich and well-connected."
Source
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Quote #1
"The appellate briefs may also shed light on the extent of “the evidence . . . that [Epstein] committed multiple offenses against a series of underage girls,”"
Source
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Quote #2
"District Attorney’s Office argued before the lower court that Epstein should be registered as a level one sex offender before changing position on appeal."
Source
HOUSE_OVERSIGHT_016499.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,080 characters)

limiting public access to judicial records or proceedings. Daily News, L.P. v. Wiley, 126 A.D.3d
511, 515, 6 N.Y.S.3d 19, 24 (1st Dep’t 2015) (before sealing records, courts “must adhere
strictly to the procedures set forth in the controlling case law including affording a full
opportunity by any interested members of the press to be heard, and making specific findings to
support its determination . . . . [T]rial court[s] . . . cannot . . . seal evidence and transcripts
merely because the parties are consenting to same and the case has obtained notoriety.”).
Therefore, in the unlikely event that this Court declines to grant the Post’s motion to unseal,
either in part or in toto, the Post respectfully requests that this Court issue a written order setting
forth the grounds for its decision.
II. GOOD CAUSE EXISTS TO UNSEAL THE APPELLATE BRIEFS
The appellate briefs should be disclosed because they are highly relevant to the public’s
understanding of whether the Office of the Manhattan District Attorney – whose fundamental
mission is to protect the people of this State – initially showed undue deference to a dangerous
pedophile, who is unusually rich and well-connected.
New York Civil Rights Law section 50-b permits courts to disclose court documents
relating to the commission of a sexual offense whenever a showing is made that “good cause
exists for disclosure.” N.Y. Civ. Rights Law § 50-b. See also 22 NYCCR § 1250.1(e)(3)
(permitting the “unsealing [of] court records . . . upon good cause shown”). Good cause clearly
exists for disclosing the appellate briefs because they contain a full explanation for why the
District Attorney’s Office argued before the lower court that Epstein should be registered as a
level one sex offender before changing position on appeal. See Epstein, 89 A.D. at 571, 933
N.Y.S.2d at 241. The appellate briefs may also shed light on the extent of “the evidence . . . that
[Epstein] committed multiple offenses against a series of underage girls,” which the District
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HOUSE_OVERSIGHT_016499

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