maintaining anonymity for the victims of sexual assault and respectfully requests that this Court also direct the District Attorney’s Office to redact the names of any victims before serving the Post with copies of the redacted appellate briefs. The Post further requests that this Court order the District Attorney’s Office to provide the Post with copies of the redacted briefs within seven days of entry of its order granting this motion. FACTUAL BACKGROUND A. Epstein’s Conviction for Sex Crimes and Designation as a Level Three Sex Offender In June 2008, a Florida Court sentenced Jeffrey Epstein to eighteen months in prison after he pleaded guilty to soliciting prostitution from a fourteen-year-old girl. Affirmation of John M. Browning dated December 21, 2018 (“Browning Aff.”), Ex. A. After serving thirteen months of his sentence, Epstein was released and required to register as a sex offender in New York, where he owned property and sought to reside. /d. Ex. B. The New York State Board of Examiners of Sex Offenders (““NYBSO”) recommended that Epstein be designated a level three sex offender — which is the level reserved for the most dangerous sexual predators — because investigators in Florida had found compelling evidence that Epstein had abused scores of underage girls, despite only pleading guilty to solicitation of a single minor. Epstein, 89 A.D.3d at 570, 933 N.Y.S.2d at 240. Remarkably, New York Assistant District Attorney Jennifer Gaffney ignored the NYBSO recommendation and asked the trial court tasked with deciding Epstein’s sex-offender status to designate him as a level one offender only, which is the least-restrictive category possible and is typically applied to offenders who pose the lowest risk of committing further crimes. Jd. ADA Gaffney argued that, since “there was only an indictment for one victim,” Epstein should not be placed under the heavy scrutiny required for the most dangerous class of abusers. /d. Ex. B. For 3 4811-3721-9459v.3 3930