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limiting public access to judicial records or proceedings. Daily News, L.P. v. Wiley, 126 A.D.3d 511, 515, 6 N.Y.S.3d 19, 24 (1st Dep’t 2015) (before sealing records, courts “must adhere strictly to the procedures set forth in the controlling case law including affording a full opportunity by any interested members of the press to be heard, and making specific findings to support its determination .... [T]rial court[s]... cannot... seal evidence and transcripts merely because the parties are consenting to same and the case has obtained notoriety.”). Therefore, in the unlikely event that this Court declines to grant the Post’s motion to unseal, either in part or in toto, the Post respectfully requests that this Court issue a written order setting forth the grounds for its decision. Il. GOOD CAUSE EXISTS TO UNSEAL THE APPELLATE BRIEFS The appellate briefs should be disclosed because they are highly relevant to the public’s understanding of whether the Office of the Manhattan District Attorney ~ whose fundamental mission is to protect the people of this State — initially showed undue deference to a dangerous pedophile, who is unusually rich and well-connected. New York Civil Rights Law section 50-b permits courts to disclose court documents relating to the commission of a sexual offense whenever a showing is made that “good cause exists for disclosure.” N.Y. Civ. Rights Law § 50-b. See also 22 NYCCR § 1250.1(e)(3) (permitting the “unsealing [of] court records . . . upon good cause shown”). Good cause clearly exists for disclosing the appellate briefs because they contain a full explanation for why the District Attorney’s Office argued before the lower court that Epstein should be registered as a level one sex offender before changing position on appeal. See Epsiein, 89 A.D. at 571, 933 N.Y.S.2d at 241. The appellate briefs may also shed light on the extent of “the evidence . . . that [Epstein] committed multiple offenses against a series of underage girls,” which the District 4811-3721-9459v.3 3930033-000039 HOUSE_OVERSIGHT_016499