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so essential to public confidence in the system.” Press-Enterprise Co. v. Superior Court, 464 U.S. 501, 508 (1984) (citing Richmond Newspapers, 448 U.S. 569-71). For this reason, the appellate briefs should be unsealed so that the public has the benefit of seeing the very statements and arguments that formed the basis of this Court’s Decision. It is especially important to provide a transparent view into these judicial proceedings because suspicions have already been raised about how the District Attorney’s Office handled Epstein’s case. When, as here, “issues of major public importance are involved, the interests of the public as well as the press in access to court records ‘weigh heavily’ in favor of release.” Danco, 274 A.D.2d at 8, 711 N.Y.S.2d at 425 (citation omitted). This constitutional presumption of open access to court records requires “the most compelling circumstances” to justify any restriction upon that right. Jn re Application of Nat’l Broad. Co., 635 F.2d at 952. Here, it is impossible to conceive of any circumstances that might justify wholesale sealing of relevant court documents that are necessary to understand how prosecutors and this Court handled a matter of such intense public concern. The interest of Epstein’s victims to remain anonymous can be satisfied by directing the District Attorney’s Office to redact the names of victims before disclosing the appellate briefs. To be clear, the Post has no interest in identifying victims of sexual assault who wish to remain anonymous. It does, however, have a right to know why the Manhattan District Attorney abruptly changed position after initially arguing that Epstein should be treated leniently. The District Attorney’s Office has indicated that it “would not oppose producing a copy of the People’s brief ... keeping intact those portions of the brief that recount the procedural history of the SORA hearing, the portion of the brief that is seemingly of interest to the Post.” Browning Aff. Ex. E. With all due respect to the District Attorney, the Post is simply not in a position to 13 4811-3721-9459v.3 3930033-000039 HOUSE_OVERSIGHT_016502