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SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION — FIRST DEPARTMENT THE PEOPLE OF THE STATE OF NEW : App. Div. No. 6081 YORK, : Respondent, : AFFIRMATION OF JOHN M. : BROWNING IN SUPPORT OF - against - MOTION TO UNSEAL JEFFREY E. EPSTEIN, : On Appeal from New York Supreme Court, Defendant-Appellant. : New York County, Index No. 30129/10 (Pickholz, J.) John M. Browning, an attorney duly admitted to practice before the Courts of the State of New York, affinns the following under penalties of perjury: 1. I am an associate of Davis Wright Tremaine LLP, attorneys for non-party movant NYP Holdings, Inc., publisher of the New York Post (the “Post”) and I submit this affirmation in support of the Post’s motion to unseal the briefs filed by the parties in the above-captioned appeal. 2. The grounds for unsealing the appeal briefs in this action are set forth in the accompanying memorandum of law. I submit this affirmation to annex relevant documents and to state facts that are relevant to this motion, of which I have personal knowledge. 3. Annexed hereto as Exhibit A is a true and correct copy of an article written by Julie K. Brown and published by the Miami Herald on November 28, 2018, entitled “Cops worked to put serial sex abuser in prison. Prosecutors worked to cut him a break.” 4. Annexed hereto as Exhibit B is a true and correct copy of an article written by Rebecca Rosenberg and Danika Fears, which was published by the Post on January 7, 2015, entitled “DA’s office ‘went easy’ on sex offender Epstein.” 4840-5788-8644v. 1 3930033 -000039 HOUSE_OVERSIGHT_016424