Non-party movant NYP Holdings, Inc., publisher of the New York Post (the “Post”), respectfully submits this memorandum of law in support of its motion, filed pursuant to 22 NYCRR § 1250.1(e)(3) and N.Y. Civil Rights Law § 50-b(2)(b), for an order unsealing the briefs filed by the parties in the above-captioned appeal (the “Appeal”) with the names of victims of sex crimes redacted. PRELIMINARY STATEMENT The Post seeks to unseal court documents that will shed light on why the Manhattan District Attorney’s Office initially sought lenient treatment of billionaire financier and convicted pedophile Jeffrey Epstein. In 2008, Epstein pled guilty to soliciting prostitution from a minor, but there has been suspicion since that time — voiced by members of the judiciary and the press alike — that prosecutors gave Epstein preferential treatment because of his wealth and his political connections to powerful men like Donald Trump, Bill Clinton, and Prince Andrew. The handling of criminal proceedings against Epstein by federal prosecutors in Florida and thereafter by the Manhattan District Attorney’s office has come under renewed scrutiny after the Miami Herald published a series of investigative articles beginning November 28, 2018, including an article reporting recently that “prosecutors worked to cut him a break” despite strong evidence that he had abused 80 girls and young women. As part of its own news reporting on the New York proceedings against Epstein, the Post seeks to unseal the briefs filed in this Appeal, in which this Court held that Epstein had to register as a level three sex offender in New York, which is the category reserved for highest-risk offenders. See People v. Epstein, 89 A.D.3d 570, 570, 933 N.Y.S.2d 239, 240 (1st Dep’t 2011). During the Appeal, Epstein argued that his sex offender status should be downgraded to a lower level while the District Attorney’s Office argued that the level-three designation was appropriate. 4811-3721-9459v.3 3930033-000039