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5. Annexed hereto as Exhibit C is a true and correct copy of an article written by Rebecca Rosenberg, Larry Celona, Susan Edelman and Isabel Vincent, which was published by the Post on December 1, 2018, entitled “Manhattan DA sided with pedophile billionaire after botching investigation.” 6. On or about December 4, 2018, Post reporter Susan Edelman contacted Danny Frost, Director of Communications for Manhattan District Attorney Cyrus Vance Jr., and requested copies of the briefs filed by the District Attorney’s office in the above-captioned appeal. Ms. Edelman stated that names of victims could be redacted before the briefs were disclosed. a Mr. Frost responded that he could not provide Ms. Edelman with copies of the briefs because they were filed under seal pursuant to N.Y. Civil Rights Law 50-b and that the District Attorney’s office could only release the briefs, even with victims’ names redacted, if this Court ordered the briefs to be unsealed. 8. Mr. Frost further indicated by email that “[i]f the Post petitions the court, and the court asks the People for our position, we will not oppose the petition for a redacted brief” (emphasis in original). A true and correct copy of that email correspondence is annexed hereto as Exhibit D. 9. On or about December 18, 2018, I contacted Jay Lefkowitz, who represented appellant Jeffrey Epstein in the above-captioned appeal. Mr. Lefkowitz told me that he no longer represents Mr. Epstein and referred me to Martin Weinberg, who currently acts as counsel for Mr. Epstein. 10. On or about December 20, 2018, I spoke with Mr. Weinberg and explained the nature of the Post’s motion to unseal the redacted briefs and the position taken by the Manhattan 4840-5788-8644v. 1 3930033-000039 HOUSE_OVERSIGHT_016425