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evaluate whether the proposed redactions are reasonable. Because the Post cannot review any
part of the briefs, it is impossible for the Post to know whether the information it seeks is in the
procedural history section of the People’s brief or in other parts of the briefing filed in the
Appeal. Moreover, courts must order narrow redactions where possible to avoid overbroad
sealing. See, e.g., Burton, 189 A.D.2d at 535-36, 597 N.Y.S.2d at 491 (requiring courts to
“consider less drastic alternatives to sealing the records which would adequately serve the
competing interests”); Maxim, Inc., 145 A.D.3d at 518, 43 N.Y.S.3d at 316 (“We recognize that
it may be easier for the parties and the motion court to seal an entire court record, rather than
make a determination on a document by document basis about sealing, but administrative
convenience is not a compelling reason to justify sealing.”). In keeping with this State’s strong
preference against wholesale sealing of documents, section 50-b expressly permits this Court to
release judicial documents after ordering redactions “as it deems necessary . . . to preserve the
confidentiality of the identity of the victim.” N.Y. Civ. Rights Law § 50-b. Since the only
information protected by the statute is identity of Epstein’s victims, the Post respectfully requests
an order directing the District Attorney to redact only the names of Epstein’s victims.³

Since the Post does not seek the names of victims of sexual abuse and agrees that these
names should be redacted before the appellate briefs are disclosed, there should be no need under
the statute to provide notice “to the victim or other person legally responsible for the care of the
victim.” N.Y. Civ. Rights Law § 50-b(2). But to the extent such notice is necessary, the Post is
unable to notify any of the victims on its own because it has no knowledge of which victims (if
any) may be identified in the requested documents. If the statute requires victims to be notified

³ Without the benefit of reviewing the appellate briefs, the Post is not in a position to evaluate whether the briefs
contain other information that might identify Epstein’s victims, such as home addresses. While the Post would not
object to the District Attorney’s Office making good faith redactions of genuinely identifying information, these
redactions should be narrowly tailored and no more expansive than is necessary to protect the victims’ identities.

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