MEMY-1805 marker2-fixhub court-us-v-maxwell-cr (pepper 16-core): 2038/2038

marker2-fixhub/court-us-v-maxwell-cr/EFTA02842896/EFTA02842896.md

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+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+-v-
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+20-CR-330 (PAE)
+
+ORDER
+
+PAUL A. ENGELMAYER, District Judge:
+
+The Court has received the attached letter from MSW Media, Inc., styled as a motion to intervene, which addresses the scope of appropriate redactions of grand jury transcripts to the extent, if any, that the Court may authorize the disclosure of these. The Court denies the motion to intervene but will take into consideration the views expressed in MSW Media's letter.
+
+SO ORDERED.
+
+PAUL A. ENGELMAYER  
+United States District Judge
+
+Dated: July 25, 2025  
+New York, New York
+
+## ATTACHMENT 1
+
+I Lit Mil KU! I I PIK' sl II I 2
+
+IU)CKVILIL MI) 20852
+
+TELEPHONE: (501) 301.4NSC (46721
+
+FACSIMILE: (240) 681.2189
+
+KEL MCCLANAHAN. ESQ., EXECUTIVE DIRECTOR (admitted in DC, NY. WA)
+
+EMAIL: KEL@NATIONALSECURITYLAW.ORG
+
+P. ESQ.. DEPUTY EXECUTIVE DIRECTOR (admitted in DC. IL)
+
+25 July 2025
+
+Hon. Paul A. Engelmayer
+
+United States District Court for the Southern District of New York
+
+Thurgood Marshall Courthouse
+
+40 Foley Square
+
+New York, NY 10007
+
+Re: United States v. Maxwell, Case No. 20-Cr-330
+
+Dear Judge Engelmayer:
+
+On behalf of MSW Media, Inc. ("MSW Media"), I respectfully submit this letter motion to intervene in the above-captioned case for the purposes of partially supporting and partially opposing the Government's motion to unseal the transcripts of grand jury testimony in this case, filed as Docket No. 785.
+
+MSW Media (https://mswmedia.com0 operates numerous podcasts and blogs about federal government operations, including Mueller She Wrote, SpyTalk, Daily Beans, and Jack. It clearly qualifies as a representative of the news media.
+
+MSW Media has standing to intervene in this case for the following reason. On 17 July 2025, after President Donald Trump publicly instructed Attorney General Pam Bondi to seek the Court's permission to release "any and all pertinent Grand Jury testimony, we filed a Freedom of Information Act ("FOIA") request with the Department of Justice ("DOJ") for transcripts of all grand jury testimony from this case and United States v. Epstein, No. 19.490 (S.D.N.Y.). We are concerned with the modifier "pertinent" in President Trump's instruction, and that concern seemed vindicated when the Government advised this Court that it intended to "make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts." (Dkt. #785 at 2 (emphasis added).)
+
+To be clear, we have no interest in victim-related information, and this Motion does not pertain to that information. However, we do have concerns that the Government seems to be implicitly seeking this Court's permission to withhold other personally identifiable information, such as information about Defendant's partners in crime or clients. Accordingly, while we join the Government in requesting that these transcripts be released, we accordingly make this narrow independent request to the Court: Please do not weigh in on the appropriateness of withholding personally identifiable information unrelated to victims. We intend to litigate this FOR request if necessary, and the question of whether such information may be properly withheld is a
+
+question best left to the court adjudicating that future case. We are concerned that, if this Court explicitly or implicitly blesses the Government's proposed redactions of non-victim-related personally identifiable information (even in passing), that opinion will be treated as a proverbial thumb on the scale in our FOIA case without materially affecting the Court's decision in this case.
+
+In other words, if this Court mentions in its decision that it was swayed at all by the Government's promise to redact personally identifiable information, we are concerned that the Government will then argue in its FOIA case that "Judge Englemayer agreed that this information should not be publicly disclosed." Therefore, we respectfully request that this Court not take the Government's statements regarding non-victim-related personally identifiable information into account when reaching its decision regarding the Government's motion, and we further request that the Court specify that it is not opining on that question, should it grant the Government's motion.
+
+The Government takes no position on the intervention of MSW Media. I attempted twice—Wednesday and Thursday—to reach Defendant's counsel and have not received a response, so I am filing this as an opposed motion due to the fast-moving nature of this case.
+
+Sincerely,
+
+l McClanahan ounsel for Proposed Intervenor

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842900/EFTA02842900.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA
+
+19 Cr. 490 (RMB)
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+UNITED STATES OF AMERICA
+
+20 Cr. 330 (PAE)
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+# GOVERNMENT'S MEMORANDUM IN RESPONSE TO THE COURT'S ORDERS OF JULY 22, 2025
+
+PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice
+
+JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278
+
+#### I. Preliminary Statement
+
+The Government respectfully submits this memorandum in response to the Court's Orders concerning the two pending motions to unseal grand jury transcripts (Epstein Dkt. 61; Maxwell Dkt. 785) in cases prosecuted in this District. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). This memorandum, as directed by the Court, addresses the specific facts and factors highlighted in the Court's Orders relevant to the particular grand jury materials at issue here. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). In order to ensure that "[t]ransparency in this process ... not be at the expense of [the Government's] obligation under the law to protect victims" (Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2), the Government also respectfully requests leave to file a supplemental submission once the Government and the Court have received any filings from the victims or others referenced in the transcripts.
+
+# II. The Court's Orders
+
+As the Court recognized (Epstein Dkt. 63 at 1-2; Maxwell Dkt. 789 at 1-2), the Second Circuit has held that "there are certain 'special circumstances' in which release of grand jury records is appropriate even outside the boundaries of the rule." In tv Craig, 131 F.3d 99, 102 (2d Cir. 1997); see also In in Biaggi, 478 F.2d 489, 494 (2d Cir. 1973) (supplemental opinion) (Friendly, C.J.) (recognizing that there are certain "special circumstances" in which release of grand jury records is appropriate even outside of the boundaries of Rule 6(e)). The Second Circuit enumerated a list of non-exhaustive factors for trial courts to consider when deciding such motions:
+
+There is currently a Circuit split. See Pitch v. United States, 953 F.3d 1226, 1233 & n.6 (11th Cir. 2020) (en banc) (describing the Circuit split); In re Petition for Order Directing Release of Records, 27 F.4th 84, 90-91 ( I st Cir. 2022) (same). In light of this split, when the Government sought similar relief seeking to unseal grand jury transcripts in the Southern District of Florida from 2005 and 2007 relating to Epstein, the Honorable who is bound by the Eleventh Circuit's rule barring extra-Rule disclosures set forth in Pitch—denied that motion. In at
+
+(i) the identity of the party seeking disclosure; (ii) whether the defendant to the grand jury proceeding or the government opposes the disclosure; (iii) why disclosure is being sought in the particular case; (iv) what specific information is being sought for disclosure; (v) how long ago the grand jury proceedings took place; (vi) the current status of the principals of the grand July proceedings and that of their families; (vii) the extent to which the desired material either permissibly or impermissibly—has been previously made public; (viii) whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and (ix) the additional need for maintaining secrecy in the particular case in question.
+
+In re Craig, 133 F.3d at 106.
+
+On July 22, 2025, the Court directed the Government to file a memorandum of law "addressing with specificity these and any other factors that the Government views as germane to its application." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). The Court also directed the Government to state whether, "before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal," and to submit: (I) indices of Epstein and Maxwell grand jury materials, including a brief summary. the number of pages, and dates; (2) a complete set of the Epstein and Maxwell grand jury transcripts; (3) a complete proposed redacted set of the Epstein and Maxwell grand jury transcripts; and (4) a description of any other Epstein and Maxwell grand jury materials, including, but not limited to, exhibits. (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3).
+
+Grand Jury 05-02 (WPB) & 07-103 (WPB), No. 25 Misc. 80920 (RLR), 2025 WL 2076030, at '1 (S.D. Fla. July 23, 2025).
+
+### III. Discussion
+
+## A. The In re Craig Factors
+
+The Court directed the Government to "address[] with specificity the0 [In re Craig] factors and any other factors that the Government views as germane to its application." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). What follows is a discussion of each of the In re Craig factors, which are designed to assist the Court in exercising its "careful judgment" in balancing the interests in public disclosure in unique circumstances of strongly expressed and wide-ranging public interest and the traditional considerations concerning the secrecy of grand jury proceedings. In re Craig, 131 F.3d at 104.
+
+### 1. The Identity of the Party Seeking Disclosure
+
+The first factor considers which party is seeking disclosure of grand jury materials; the identity of the party seeking disclosure "carr[ies) great weight." In re Craig, 131 F.3d at 106. Here, the Government is seeking disclosure of grand jury transcripts, a request that is consistent with increasing calls for additional disclosures in this matter.2 The Government's position "serve[s] as a preliminary indication that the need for secrecy is not especially strong," even if it is "not dispositive." Id.; see also id. ("Government support cannot 'confer' disclosure, nor can government opposition preclude it."). While the Government acknowledges the extraordinary
+
+{sup}`2` See, e.g., Press Release, Chairman Corner Subpoenas Ghislaine Maxwell for Deposition at Federal Prison - United States House Committee on Oversight and Accountability ("The facts and circumstances surrounding both [Ms. Maxwell] and Mr. Epstein's cases have received immense public interest and scrutiny. At the outset of the 119th Congress, on February 11, 2025, the Committee and the Task Force on the Declassification of Federal Secrets sent a letter to the U.S. Department of Justice requesting a briefing regarding documents in the Department's possession regarding 'the investigation into and prosecution of Jeffrey Epstein.' On May 8, the Task Force sent another letter to the Department requesting the public release of 'the entirety of the Epstein files' and a briefing regarding the release of these files.").
+
+nature of the instant request, it is also (like the Court) faced with a broad public interest in the underlying proceedings.
+
+### 2. Whether the Defendant to the Grand Jury Proceeding or the Government Opposes the Disclosure
+
+The second factor asks whether the defendant or the Government opposes public disclosure of grand jury materials. See In re Craig, 131 F.3d at 106; see also Lawyers' Committee for 9/11 Inquiry Inc. v. Garland, 43 F.4th 276, 285-86 (2d Cir. 2022) (affirming denial of motion to disclose grand jury materials where the Government opposed release). A defendant's opposition to public disclosure is not dispositive. See In re Grand Jury Proceedings GJ-76-4 & GJ-75-3, 800 F.2d 1293, 1305 (4th Cir. 1986) (affirming district court's decision to disclose grand jury transcript and exhibits over defendant corporation's objection).
+
+Defendant Epstein has passed and therefore cannot assert a position.3 Defendant Maxwell has indicated that she expects "to craft a response and set out [her] position to the Court." (Maxwell Dkt. 793).
+
+## 3. Why Disclosure Is Being Sought in the Particular Case
+
+The third factor considers "why disclosure is being sought in the particular case." In re Craig, 131 F.3d at 106. The Second Circuit in In re Craig held: "It is ... entirely conceivable that in some situations historical or public interest alone could justify the release of grand jury information." Id. As described above and in the underlying motions, there is undoubtedly a clearly expressed interest from the public in Jeffrey Epstein's and Ghislaine Maxwell's crimes. Beyond that, there is abundant public interest in the investigative work conducted by the Department of Justice and the Federal Bureau of investigation into those crimes. See In iv Am. Hist. Assn, 49 F.
+
+{sup}`3` As noted below, the Government has not received any outreach from Epstein's surviving family concerning the instant motion.
+
+Supp. 2d 274, 294 (S.D.N.Y. 1999) (applying In re Craig) ("Many historians ... have spent countless hours documenting the Rosenbergs' story. Many questions remain unanswered, and the public's interest remains."); (Epstein Dkt. 61 at 1; Maxwell Dkt. 785 at I). Attention given to the Epstein and Maxwell cases has recently intensified in the wake of the July 6, 2025 Memorandum announcing the conclusions of the Government's review into the investigation. See id.
+
+The instant motions for unsealing are consistent with the fundamental purposes set forth in that memorandum given the magnitude and abhorrence of Epstein's crimes: to provide information to the public while remaining sensitive to protecting the rights of victims.
+
+# 4. What Specific Information Is Being Sought for Disclosure
+
+The fourth factor asks what specific information the movant seeks to disclose. See In re Craig, 131 F.3d at 106. Here, the Government seeks the public disclosure of the grand jury transcripts in the Epstein and Maxwell cases (Epstein Dkt. 61 at I; Maxwell Dkt. 785 at I ). As stated in the pending motions, any public disclosure granted by the Court would be "subject to appropriate redactions of victim-related and other personal identifying information" (Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2).
+
+## 5. How Long Ago the Grand Jury Proceedings Took Place
+
+The fifth factor asks how long ago the grand jury proceedings took place. In re Craig, 131 F.3d at 106. The grand jury met in June and July of 2019 in the Epstein case. The grand jury met in June and July of 2020 and March of 2021 in the Maxwell case. Here, the passage of time has not dulled the public's interest in these cases. See In re Craig, 131 F.3d at 107 Cif historical interest in a specific case has persisted over a number of years, that serves as an important indication that the public's interest in release of the information is substantial").
+
+#### 6. The Current Status of the Principals of the Grand Jury Proceedings and that of their Families
+
+The sixth factor considers "the current status of the principals of the grand jury proceedings and that of their families." In re Craig, 131 F.3d 99. The passage of time "brings about the death of the principal parties involved in the investigations, as well as that of their immediate families." Id. at 106. The Court should consider the "continued existence and vulnerabilities of such parties." Id.
+
+In this case, the grand jury testimony was offered specifically in connection with charges proposed against Epstein and Maxwell. Epstein is deceased, and no family member has approached the Government indicating an interest in the instant motions. One of Epstein's family members previously filed a request for materials pursuant to the Freedom of Information Act, the Government responded to that request, and no litigation ensued. Maxwell currently is incarcerated, and no family member has approached the Government indicating an interest in the motions.
+
+### 7. The Extent to Which the Desired Material-Either Permissibly or Impermissibly—Has Been Previously Made Public
+
+The Government is not aware of the relevant grand jury transcripts being impermissibly leaked to the public.
+
+Certain aspects and subject matters of the transcripts became public during Maxwell's trial. To the extent that any of the desired material was disclosed to Maxwell as a result of the Government's disclosure obligations, it was disclosed pursuant to a protective order.
+
+Many of the victims whose accounts relating to Epstein and Maxwell that were the subject of grand jury testimony testified at trial consistent with the accounts described by an FBI agent and the detective from the New York City Police Department ("NYPD") in the grand jury and some have also made public those factual accounts in the course of civil litigation. The
+
+Government is providing under seal a list of witnesses whose accounts were conveyed in the grand jury proceedings and a corresponding list noting which witnesses testified at trial.
+
+### 8. Whether Witnesses to the Grand Jury Proceedings Who Might Be Affected by Disclosure Are Still Alive
+
+The eighth factor considers "whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive." In re Craig, 131 F.3d at 106.
+
+Here, there was one witness—an FBI agent—during the Epstein grand jury proceedings. There were two witnesses—the same FBI agent from the Epstein grand jury proceedings and a detective with the NYPD who was a Task Force Officer with the FBI's Child Exploitation and Human Trafficking Task Force—during the Maxwell grand jury proceedings.
+
+Both witnesses are still alive; the FBI agent continues to be an agent with the FBI, and the Detective continues to be a Detective with the NYPD as well as a Task Force Officer.
+
+Consistent with applicable rules concerning the admissibility of hearsay testimony, the grand jury witnesses described statements of others, including statements of and concerning victims, many of whom are still alive. In the sealed submission accompanying this filing, the Government will note which victims are still alive.
+
+## 9. Whether There Is an Additional Need for Maintaining Secrecy in the Particular Case in Question
+
+Finally, the ninth factor considers "the additional need for maintaining secrecy in the particular case in question." In re Craig, 131 F.3d at 106. In addition to the typical reasons for grand jury secrecy, the grand jury transcripts contain victim•related and other personal identifying information related to third parties who neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell were charged, to which the Government is sensitive, and which is why the Government proposes redacting the transcripts before releasing them. (See Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2).
+
+#### B. Additional Information
+
+The Court directed the Government to state whether, "before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal." (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3).
+
+Before filing the motions to unseal, relevant counsel for the Government reviewed the Epstein and Maxwell grand jury transcripts. In addition, the Government has now provided notice to all but one of the victims who are referenced in the grand jury transcripts at issue in this motion. The Government has attempted to contact the remaining victim, but such efforts have been unsuccessful. In addition, the Government is in the process of providing notice to any other individuals identified in the transcripts.
+
+## C. Provision of Materials to the Court
+
+The Court directed the Government to submit: (I) indices of Epstein and Maxwell grand jury materials, including a brief summary, the number of pages, and dates; (2) a complete set of the Epstein and Maxwell grand jury transcripts; (3) a complete proposed redacted set of the Epstein and Maxwell grand jury transcripts; and (4) a description of any other Epstein and Maxwell grand jury materials, including, but not limited to, exhibits. (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). As to the final category, the Government provides a description of all of the underlying materials presented to the grand jury as well as copies of, and proposed redactions to, certain materials presented to the grand jury.
+
+The Government is submitting these materials ex pane and under seal, as they relate to grand jury proceedings and include information related to victims, including but not limited to victim-identifying information of individuals who neither testified at trial or who were the subject of testimony at trial. The Government underscores that it takes very seriously its obligation to protect victim-related information and therefore believes the proposed redactions not only are appropriate but are necessary to protect those rights.
+
+Dated: New York, New York July 29, 2025
+
+Respectfully submitted,
+
+PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice
+
+/s/ Jay Clayton
+
+JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842910/EFTA02842910.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+-v-
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+20 Cr. 330 (PAE)
+
+ORDER
+
+PAUL A. ENGELMAYER, District Judge:
+
+The Government's application to unseal the grand jury transcripts in this case is pending before the Court, Dkt. 785, and the Government's July 29, 2025 submission suggests, although it does not squarely state, that the Government is seeking as well to unseal the exhibits put before the grand jury, Dkt. 796. As proposed by the Government, the items disclosed would be redacted so as not to disclose victim-related or other personally identifiable information. Dkt. 785 at 2. The Government has furnished the Court with the transcripts and exhibits, indicating as to each the portions that the Government proposes to redact if the motion to unseal is granted.
+
+To assist the Court in its review of this application, the Court directs the Government, by Monday, August 4, 2025, to provide the Court with a letter:
+
+- 1. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts, or just the transcripts.
+- 2. Identifying with specificity the grand jury exhibits, as redacted for proposed release, that are not already part of the public record. In making this assessment, the Government should take into account whether the unredacted portions of these
+
+exhibits were received in evidence during trial in this case, otherwise disclosed on the docket of this case, or disclosed in the course of civil litigation, *see, e.g.*, [REDACTED] v. *Maxwell*, 15 Civ. 7433 (LAP).
+
+1. 3. Identifying with specificity the information testified to in the grand jury transcripts, as redacted for proposed release, that is not already part of the public record, taking into account the sources above.
+
+The Government is authorized to publicly file, in redacted form, its letter responding to this order.
+
+SO ORDERED.
+
+
+
+---
+
+PAUL A. ENGELMAYER  
+United States District Judge
+
+Dated: July 31, 2025  
+New York, New York

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842912/EFTA02842912.md

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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x
+
+UNITED STATES OF AMERICA,
+
+— against —
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+x
+
+20 Cr. 330 (ME)
+
+## DECLARATION OF CHRISTIAN R. EVERDELL IN SUPPORT OF MOTION TO WITHDRAW AS CO-COUNSEL
+
+I, CHRISTIAN R. EVERDELL, declare as follows:
+
+1. I am a partner at the law firm & Gresser LLP ("C&G"), co-counsel for defendant Ghislaine Maxwell. I am fully familiar with the facts set forth herein and respectfully submit this declaration pursuant to Local Civil Rule 1.4, Local Criminal Rule I.1(b) (making Local Civil Rule 1.4 applicable to criminal proceedings), and Local Criminal Rule 1.2, in support of C&G's motion to withdraw as co-counsel for defendant Ghislaine Maxwell in the abovecaptioned matter.
+
+2. Ms. Maxwell retained C&G to represent her in the above-captioned matter. Mark and I filed notices of appearance on July S. 2020. C&G represented Ms. Maxwell at trial and through her sentencing on June 28, 2022.
+
+3. Ms. Maxwell's sentencing concluded her district court proceedings. Ms. Maxwell filed a notice of appeal on July 7, 2022. C&G did not represent Ms. Maxwell in her appellate proceedings.
+
+4. On July 18, 2025, Deputy Attorney General Todd Blanche appeared in this case on behalf of the government and filed a motion to unseal grand jury transcripts.
+
+5. On July 22, 2025, David Markus and Melissa Madrigal of Markus IIMPLLC ("Markus appeared as counsel of record in this case for Ms. Maxwell.
+
+6. I have spoken with Mr. Markus who has confirmed that Ms. Maxwell has retained Markus to handle the government's unsealing motion and that he is prepared to meet any deadlines imposed by the Court.
+
+7. Mr. Markus has also informed me that he has discussed this motion with Ms. Maxwell and she consents to C&G's withdrawal from this matter.
+
+8. C&G is not asserting any liens in this matter and will share its files with Markus upon request. subject to the conditions imposed by the protective order in this case (Dkt. No. 36).
+
+9. C&G has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.
+
+{sup}`I`declare under apenalty of perjury pursuant to 28 U.S.C. 1746 that the foregoing is true and correct.
+
+Dated: August 1, 2025 New York, New York
+
+Respectfully submitted,
+
+& GRESSER LLP
+
+Christian R. Everdell 800 Third Avenue, 21' Floor New York, NY 10022 Phone: (212) 957-7600 Fax: (212) 957-4514 ceverdell@cohengresser.com
+
+Attorneys for Ghislaine Maxwell

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842914/EFTA02842914.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+— against -
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+X
+
+20 CR. 330 (PAE)
+
+## (PROPOSED, ORDER GRANTING MOTION TO WITHDRAW
+
+Upon consideration of the Motion to Withdraw, it is HEREBY ORDERED THAT Christian R. Everdell and Mark S. of & Gresser LLP are granted leave to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.
+
+Dated: , 2025
+
+The Honorable Paul A. Engelmayer United States District Judge

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842915/EFTA02842915.md

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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+— against —
+
+GHISLAINE MAXWELL,
+
+• •
+
+Defendant. •
+
+- X
+
+20 Cr. 330 (PAE)
+
+## NOTICE OF MOTION TO WITHDRAW
+
+PLEASE TAKE NOTICE that, upon the accompanying Declaration of Christian R. Everdell, I respectfully move this Court for an Order pursuant to Local Rule 1.4 permitting myself, Mark S. =, and & Gresser LLP to withdraw as co-counsel for defendant Ghislaine Maxwell.
+
+Dated: August I, 2025 New York, New York
+
+Respectfully submitted,
+
+& GRESSER LLP
+
+Christian It Everdell Mark S. 800 Third Avenue, 21' Floor New York, NY 10022 Phone: (212) 957-7600 Fax: (212) 957-4514 ceverdellQcohengresser.com mcohen@cohengresser.com
+
+Attorneys for Ghislaine Maxwell

marker2-fixhub/court-us-v-maxwell-cr/EFTA02842915/EFTA02842915.receipt.json

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842916/EFTA02842916.md

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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x
+
+UNITED STATES OF AMERICA,
+
+— against --
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+X
+
+20 CR. 330 (ME)
+
+## ORDER GRANTING MOTION TO WITHDRAW
+
+Upon consideration of the Motion to Withdraw, it is HEREBY ORDERED THAT Christian R. Evcrdcll and Mark S. of & Dresser LLP are granted leave to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.
+
+Dated: August 4 , 2025
+
+Pea Cilialfr
+
+The Honorable Paul A. ngclmayer United States District Judge

marker2-fixhub/court-us-v-maxwell-cr/EFTA02842916/EFTA02842916.receipt.json

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842917/EFTA02842917.md

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+![](_page_0_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The Honorable Richard M. Berman United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007
+
+> Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE)
+
+The Jacob K. Javits Federal Building 26 Federal Plaza. 37th Floor New York. New York 10278
+
+
+The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, New York 1007
+
+Dear Judges Berman and Engelmayer:
+
+The Government writes respectfully to respond to the Court's orders, dated July 31, 2025, directing the Government to provide additional information regarding grand jury materials the Government has asked the Court to unseal in these cases. (Epstein Dkt. 67; Maxwell Dkt. 797).
+
+In particular, on July 18, 2025, the Government moved the Court to unseal grand jury transcripts from these cases, subject to appropriate redactions. (Epstein Dkt. 61; Maxwell Dkt. 785). The Court directed the Government to provide supplemental briefing (Epstein Dkt. 63; Maxwell Dkt. 789), which the Government submitted on July 29, 2025 (Epstein Dkt. 66; Maxwell Dkt. 796). In addition, the Court set a schedule whereby the defendants and victims could set out their positions on or before August 5, 2025. (Epstein Dkt. 63 at 3-4; Maxwell Dkt. 789 at 4).
+
+On July 31, 2025, the Court directed the Government to provide additional information by August 4, 2025, in particular, in the Epstein case, a letter:
+
+- I. Verifying the date(s) of all grand jury presentation(s) in this case;
+- 2. Providing all exhibits shown to grand jurors;
+- 3. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts;
+- 4. Identifying with specificity the grand jury exhibits that are not already part of the public record (They may be redacted for any public release);
+
+Hon. Richard M. Berman, U.S.D.J. Hon. Paul A. Engelmayer, U.S.D.J. August 4, 2025 Page 2 of 4
+
+- 5. Analyzing how the Nolle Prosequi ([Epstein] ECF No. 52) filed in this case impacts proposed disclosure, with legal authorities.
+
+(Epstein Dkt. 67). In the Maxwell case, the Court directed the Government to provide additional information by August 4, 2025, in particular, a letter:
+
+- 1. Stating whether the Government moves to unseal the grand jury exhibits as well as the transcripts, or just the transcripts.
+- 2. Identifying with specificity the grand jury exhibits, as redacted for public release, that are not already part of the public record. In making this assessment, the Government should take into account whether the unredacted portions of these exhibits were received in evidence during trial in this case, otherwise disclosed on the docket of this case or disclosed in the course of civil litigation, see, e.g., v. Maxwell, 15 Civ. 7433 (LAP).
+- 3. Identifying with specificity the information testified to in the grand jury transcripts, as redacted for proposed release, that is not already part of the public record, taking into account the sources above.
+
+(Maxwell Dkt. 797).
+
+Because the Court's Orders, and the information sought, are consistent in several respects, the Government respectfully submits this consolidated letter response.
+
+First, at this time, the Government has moved only to unseal the grand jury transcripts in these cases. Of course, the grand jury exhibits are not the only exhibits in these cases; a large number of exhibits were admitted at the Maxwell trial, which trial exhibits are—subject to judicially approved redactions and/or sealing—presumptively public documents. See, e.g., United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) ("the public has an especially strong right of access to evidence introduced in trials" (internal quotation marks and citation omitted)); United States v. Akhavan, 532 F. Supp. 3d 181, 186 (S.D.N.Y. 2021) ("trial exhibits are judicial documents to which an 'especially strong' common law presumption of access applies" (quoting Amodeo, 71 F.3d at 1049)). The Government previously made those trial exhibits—subject to any judicially approved redactions and/or sealing—available to the public through a website during the Maxwell trial.
+
+The Government respectfully requests leave of the Court to advise the Court by August 8, 2025, of its position with respect to unsealing of the grand jury exhibits. Such timing will permit the Government to consider (with respect to its underlying position as well as with respect to any
+
+Hon. Paul A. Engelmayer, U.S.D.J.
+
+
+
+
+necessary redactions) any submissions to the Court by the victims identified in the grand jury transcripts, which are due to the Court on August 5, 2025.
+
+Second, the Epstein grand jury met on June 18, 2019, and July 2, 2019. The Maxwell grand jury met on June 29, 2020, July 8, 2020, and March 29, 2021.
+
+Third, the Government has provided the Court with all substantive exhibits from the grand jury presentations in each of the Epstein and Maxwell cases that it currently has in its possession. The Government respectfully submits under seal to Judge Berman one additional grand jury exhibit from the Epstein case that it referenced in its letter to the Court but did not have readily available at that time.
+
+Fourth, in connection with this letter, the Government respectfully submits to Judge Engelmayer under seal and ex parte a version of the Maxwell grand jury transcripts that specifically identifies which information in the transcripts is not, as far as the Government is aware, publicly available. As previewed in the Government's submission of July 29, 2025, many of the victims and witnesses testified at trial consistent with the accounts offered in the grand jury by investigating law enforcement witnesses. The enclosed, annotated transcripts show that much of the information provided during the course of the grand jury testimony—with the exception of the identities of certain victims and witnesses—was made publicly available at trial or has otherwise been publicly reported through the public statements of victims and witnesses.'
+
+Fifth, the substantive grand jury exhibits are not currently part of the public record. The Government, however, is undertaking to identify for the Court any specific portions of the grand jury exhibits that are reflected in the public record. In doing so, the Government endeavors to compare the exhibits against the voluminous public and sealed exhibits offered at the Maxwell trial and to review certain relevant civil litigation dockets of which the Government is aware to the extent such dockets are publicly available. The Government respectfully requests leave of the Court to supplement this letter no later than August 8, 2025, in order to respond to item 4 of Judge Berman's Order and item 2 of Judge Engelmayer's Order.
+
+Sixth, the nolle prosequi filed in the Epstein case does not impact the proposed disclosure. While the Supreme Court has noted—in a different context—that a Court's "jurisdiction end[s]" when "a nolle prosequi [is] entered," Ex parte Wilson, 140 U.S. 575, 583 (1891), it did so in the context of a court having the ability to enter a judgment. To the contrary, at least one court has explicitly held that a nolle prosequi does not deprive a court of the authority to determine whether to disclose sealed grand jury minutes. United States v. Byoir, 58 F. Supp. 273, 274 (N.D. Tex.),
+
+Although there was no public trial of Epstein, the Government is prepared to do a similar analysis regarding the Epstein grand jury transcripts if Judge Berman believes it would assist in the Court's analysis of the In re Craig factors related to the Government's motion in Epstein.
+
+Hon. Paul A. Engelmayer, U.S.D.J.
+
+
+
+
+affirmed 147 F.2d 336 (5th Cir. 1945) ("The same jurisdiction that was sought in the beginning continues to exist insofar as the integrity and preservation of the minutia and minutes and proceedings of those steps are concerned. What was done here is evidence and may be advantaged by either party, having in mind, of course, the question of the secrecy of the grand jury proceedings. And the only jurisdiction over such matters is in this court"); see also, e.g., Dale v. Bartels, 532 F. Supp. 973, 978-79 (S.D.N.Y. 1982) (ordering limited disclosure of sealed grand jury testimony after entry of a nolle prosequi). However, the fact that Epstein passed away—which was the basis for the entry of the nolle prosequi—is a factor to be considered. See In re Craig, 131 F.3d 99, 106 (2d Cir. 1997) (noting that "the current status of the principals of the grand jury proceedings and that of their families" is a factor "that a trial court might want to consider when confronted with these highly discretionary and fact-sensitive 'special circumstances' motions").
+
+Seventh, regarding the Government's approach to victim notification of the instant proceedings, as noted in its July 29 submission, the Government has provided notice of the unsealing motions to all but one of the victims who are referenced in the grand jury transcripts at issue in the motions. The Government still has been unable to contact that remaining victim. With respect to victims who are not identified in the grand jury transcripts but who have previously received victim notifications in the Maxwell and Epstein matters, the Government will over the coming days alert those victims to the fact of the unsealing motions.
+
+Finally, in light of the Government's ongoing efforts to ensure that that the interests of victims and other third parties are appropriately considered, as well as the multifaceted nature of these and other relevant proceedings, it may be necessary or appropriate for the Government to modify or supplement the information provided today, and the Government commits to doing so as promptly as practicable.
+
+As always, the Government is available to answer any questions the Court may have.
+
+Respectfully submitted,
+
+PAMELA J. BONDI
+
+United States Attorney General
+
+TODD BLANCHE
+
+Deputy United States Attorney General
+
+United States Department of Justice
+
+/s/ Jay Clayton
+
+JAY CLAYTON
+
+United States Attorney for the
+
+Southern District of New York
+
+26 Federal Plaza
+
+37th Floor
+
+New York, New York 10278

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842921/EFTA02842921.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+20 Cr. 330 (PAE)
+
+-v-
+
+ORDER
+
+OHISLA1NE MAXWELL,
+
+Defendant.
+
+PAUL A. ENGELMAYER, District Judge:
+
+The Government's motion to unseal certain grand jury materials in this case is pending before the Court. Dkt. 785; see also Dkt. 796. On July 22, 2025, the Court ordered, inter alia, that any letters by or on behalf of victims in this case setting out their positions vis-a-vis the Government's motion be submitted on or before Tuesday, August 5, 2025. Dkt. 789. The Court here provides additional logistical instructions for any such submissions by victims.
+
+Any victim in this case seeking to submit a letter regarding the Government's proposed disclosure shall, by Tuesday, August 5, 2025, send the letter to:
+
+SDNY Victim and Witness Coordinator United States Attorney's Office 26 Federal Plaza, 37th Floor New York, New York 10278 1-866-874-8900 USANYS.EpsteinMaxwellVictims®usdoj.gov
+
+The Government shall then provide the following materials to the Court, by hand, by 3 p.m. on Wednesday, August 6, 2025: (1) all such victim submissions in unredacted form, which the Court will retain under seal; and (2) a version of the same suitable for public docketing, with proposed redactions to protect any personal identifying information.
+
+SO ORDERED.
+
+Dated: August 5, 2025 New York, New York Pad A en
+
+PAUL A. ENGELMAYE United States District Judge

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842923/EFTA02842923.md

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+## UNITED STATES DISTRICT COURT SOUTIIERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+20 Cr. 330 (PAE)
+
+-v-
+
+## ORDER
+
+GI IISLAINE MAXWELL,
+
+Defendant.
+
+PAUL A. ENGELMAYER, District Judge:
+
+This order sets a deadline for the Government's outstanding filings in connection with its pending motion to unseal certain grand jury materials in this case. Dkt. 785.
+
+On July 29, 2025, the Government, in its memorandum of law in support of that motion, sought leave to file a supplemental submission responding to submissions from victims, which are due today, August 5, 2025. Dkt. 796 at 2. And, on August 4, 2025, the Government filed a letter stating that, although thus far it has moved to unseal only the grand jury transcripts in this case, it is considering whether also to seek unsealing of the grand jury exhibits, and sought leave to notify the Court by August 8, 2025, of its position on that point. Dkt. 800 at 2-3.
+
+The Court grants these requests for leave to file supplemental submission(s) addressing these points. It sets a deadline of Friday, August 8, 2025 for the Government to file:
+
+- 1. Its response, if any, to any letters submitted by or on behalf of victims, and/or to any submission by defendant Maxwell (which is also due today); and
+- 2. Its statement as to whether its motion to unseal (with appropriate redactions) covers the grand jury exhibits (or merely the grand jury transcripts).
+
+The Government is authorized to file these submissions in redacted form publicly, to respect victims' privacy interests.
+
+SO ORDERED.
+
+Patitz A 6/lehr
+
+PAUL A. ENGELMAYER United States District Judge
+
+Dated: August 5, 2025 New York, New York

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842925/EFTA02842925.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA, 20-CR-330 (PAE)
+
+vs.
+
+GHISLAINE MAXWELL. /
+
+### GHISLAINE MAXWELL'S RESPONSE IN OPPOSITION TO GOVERNMENTS MOTION TO UNSEAL GRAND JURY TRANSCRIPTS
+
+Although the government did not oppose allowing the defense to review the grand jury material to assess whether to object to its release, the Court denied that request. As a result, Ghislaine Maxwell has not seen the material and cannot take an informed position. Given that she is actively litigating her case and does not know what is in the grand jury record, she has no choice but to respectfully oppose the government's motion to unseal it.
+
+# I. INTRODUCTION
+
+Jeffrey Epstein is dead. Ghislaine Maxwell is not. Whatever interest the public may have in Epstein, that interest cannot justify a broad intrusion into grand jury secrecy in a case where the defendant is alive, her legal options are viable, and her due process rights remain.
+
+When Epstein died, prosecutors from the Southern District of New York pivoted and made Maxwell the face of his crimes. She became the scapegoat and the only person the government could put on trial. She was convicted in a media firestorm of false reporting and mischaracterization of evidence. Now, with her case pending before the Supreme Court, the government seeks to unseal untested,
+
+hearsay-laden grand jury transcripts, which contain statements presented in secret and never challenged by the adversarial process. Maxwell has never been allowed to review those transcripts even though the government did not oppose her recent request to do so.
+
+The government seeks to unseal the grand jury transcripts, citing "historical interest" without regard for how that release will affect Maxwell's privacy interests, her pending Petition, and any future litigation. The government's Memorandum (Dkt. 796) cloaks itself in In re Craig, but that case emphasized that disclosure requires the most careful judgment and that "the public's curiosity in a defendant's secret conduct at a grand jury hearing cannot eclipse the right the defendant has to secrecy and overwhelm his objection to public discourse." 131 F.3d 99, 105 (2d Cir. 1997).
+
+Because this is ongoing litigation in a criminal case involving a living defendant with existing legal remedies, the government's motion should be denied.
+
+## II. THE GOVERNMENT FAILS TO ESTABLISH "SPECIAL CIRCUMSTANCES" WARRANTING DISCLOSURE OF GRAND JURY MATERIALS IN AN ONGOING CASE
+
+There is a tradition in the United States that is "older than the Nation itself," that grand jury proceedings shall remain secret. In re Craig, 131 F.3d at 101-02 (quoting In re Biaggi, 478 F.2d 489, 491 (2d Cir.1973)). This tradition of secrecy is codified in Federal Rule of Criminal Procedure 6(e). The rule of secrecy is not without exceptions, however, and Rule 6(e)(3) lists several exceptions. The Second Circuit has additionally recognized that there are certain "special circumstances" in which
+
+release of grand jury records is appropriate even outside the boundaries of Rule 6(e)(3). In re Craig, 131 F.3d at 102. Importantly, "the discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make." Id. at 104.
+
+In re Craig involved a petition by a doctoral candidate to unseal the nearly 50 year-old grand jury testimony of a high-ranking government employee, Harry Dexter based on historical interest in suspected role as a communist spy. The court in In re Craig denied the petition to unseal. On appeal, the Second Circuit affirmed the trial court's denial of the petition, finding that the court did not abuse its discretion when it found that sufficiently exceptional circumstances did not exist to warrant disclosure. Id. at 100-01, 107.
+
+In affirming the lower court's denial of the motion to unseal, the Second Circuit acknowledged historical interest as a potential basis for disclosure and offered a nonexhaustive list of factors that a trial court might consider when confronted with ruling on a motion to unseal. Id. at 105-06. Those factors include, but are not limited to:
+
+> (i) the identity of the party seeking disclosure; (ii) whether the defendant to the grand jury proceeding or the government opposes the disclosure; (iii) why disclosure is being sought in the particular case; (iv) what specific information is being sought for disclosure; (v) how long ago the grand jury proceedings took place; (vi) the current status of the principals of the grand jury proceedings and that of their families; (vii) the extent to which the desired material—either permissibly or impermissibly—has been previously made public; (viii) whether witnesses to the grand jury proceedings who might
+
+be affected by disclosure are still alive; and (ix) the additional need for maintaining secrecy in the particular case in question.
+
+In re Craig, 131 F.3d at 106. The Court noted that "all of these factors and their precise significance must be evaluated in the context of the specific case." Id. at 107.
+
+The timing of a request to unseal is "one of the most crucial elements" to be considered by a district court. In re Craig, 131 F.3d at 107. Here, the grand jury convened just five years ago, not decades ago. This is not a case where the "passage of time erode[d] many of the justifications for continued secrecy." Id. Nor is it a case where time has brought about the "death of the principal parties involved in the investigations, as well as that of their immediate families." Id. at 107. Epstein may be dead, but Maxwell is alive and litigating her case.
+
+Maxwell's Petition for a Writ of Certiorari is pending before the Supreme Court. She is preparing a habeas petition. Disclosure of grand jury materials at this stage risks irreparably tainting the legal process by injecting sealed testimony into the public debate while judicial review is ongoing. The reputational harm from releasing incomplete, potentially misleading grand jury testimony, untested by crossexamination, would be severe and irrevocable. Those allegations, if released in raw, untested form, would inevitably influence any future legal proceeding should Maxwell succeed in her post-conviction litigation. The government's proposal to "redact victim-identifying information" does not mitigate this harm. The substance of the allegations, not the names, creates the prejudice. Public curiosity is insufficient
+
+when Maxwell's legal and reputational interests are at stake. These factors weigh heavily in favor of preserving the secrecy of the grand jury materials.
+
+Although the government's memorandum sets forth that certain "aspects and subject matters of the transcript became public during Maxwell's trial," Maxwell has never had an opportunity to review the entirety of the grand jury materials in her case. Dkt 796 at 7. The government provided a list to the Court, under seal, of witnesses whose accounts were conveyed in the grand jury and a corresponding list noting which witnesses testified at trial. That list has not been disclosed to us. The government's memorandum, however, acknowledges that the law enforcement witnesses who testified before the grand jury are alive and remain active in the FBI and NYPD respectively. The government's memorandum also disclosed that "many" of the complaining witnesses, who formed the subject matter of the grand jury witnesses' testimony, are also alive. Dkt 796 at 8. This factor likewise counsels against disclosure of the grand jury transcripts given the need to protect both active law enforcement personnel and alleged victims.
+
+# III. THERE IS NO PRECEDENT SUPPORTING RELEASE OF GRAND JURY TRANSCRIPTS IN A PENDING CASE LIKE THIS ONE
+
+None of the cases cited by the government justify disclosure here. In re Petition of National Security Archive involved a decades-old grand jury proceeding against Julius and Ethel relating to charges of conspiracy to commit espionage by providing information about the atomic bomb to Soviet agents. 104 F. Supp. 3d 625, 626 (S.D.N.Y. 2015). In 1951, the Rosenbergs were tried, convicted, and sentenced to death. They were executed in 1953. Id. In 2015, upon a motion by a non-profit
+
+institution and others, Judge Hellerstein granted a petition to unseal the grand jury testimony of David Greenglass, Ethel brother. In granting the petition to unseal Greenglass' grand jury testimony, the court observed that in the 65 years that had passed since the trial, many believed that Ethel was innocent and had been framed by Greenglass. Id. at 628. As a result, and only after Greenglass had passed away, the court concluded that Grenglass' grand jury testimony should be released since it provided information in a case of historical interest to the public. Id. at 629 (holding that "the requested records are critical pieces of an important moment in our nation's history" and "the time for the public to guess what they contained should end.'). It is noteworthy that Judge Hellerstein refused to unseal the transcript while Grenglass was alive, finding that Greenglass' interest in preserving the secrecy of his grand jury testimony "was sufficient to prevent its unsealing during his life, despite the public interest in the case." Id. at 628.
+
+In re Petition of American Historical Association involved a similar request by historical associations in 1998 to unseal transcripts of two special grand juries convened from 1947 to 1950 pertaining to the espionage investigation of Alger Hiss. In re Am. Hist. Ass'n, 49 F. Supp. 2d 274 (S.D.N.Y. 1999). Hiss, a former high-ranking State Department official, was convicted of committing perjury in responding to allegations that he was a Soviet spy. Hiss maintained his innocence until his death and publicly suggested that his prosecution was a political hit job by Richard Nixon to mobilize public opposition to communism. Id. at 294. In granting the request to unseal the fifty-year old grand jury materials, the court noted the significant passage of time along with the fact that most of the relevant witnesses, including Hiss, had died. Id. at 293. The court ultimately ruled that the great historical importance of the Hiss case outweighed the minimal interest in preserving secrecy. Id. at 293 (noting that alleged Soviet espionage against the United States was a controversial and historically significant issue in domestic politics during the 1940s and 1950s, and to the present day).
+
+Disclosure is being sought in this case due to immense public interest in Jeffrey Epstein's and Ghislaine Maxwell's cases, along with public interest in the government's handling of those investigations and prosecutions. The public interest identified by the government—while understandable—is insufficient to warrant disclosure of grand jury materials at this time. The government frames this interest as "historical," yet it is nothing more than widespread and intense public curiosity about an ongoing criminal case. Neither In re Petition of National Security Archive, nor In re Petition of American Historical Association, support the conclusion that the Maxwell grand jury materials should be released. Each of those cases involved testimony dating back at least five decades, along with grand jury testimony relating to defendants and witnesses who were deceased.
+
+In re Biaggi is equally unavailing. In re Biaggi, 478 F.2d 489 (2d Cir. 1973). That case involved the unsealing of grand jury testimony of a U.S. Congressman, Mario Biaggi, who had not been indicted, and who waived any protection to secrecy by "seeking complete disclosure in the form of a motion requesting disclosure of his own testimony for its own sake." In re Biaggi, 478 F.2d 489, 493 (2d Cir. 1973). The government in In re Biaggi moved to unseal Biaggi's grand jury testimony only after Biaggi petitioned a three-judge panel in the Southern District of New York to examine his grand jury testimony and publicly report whether he had invoked any constitutional privileges relating to his personal finances or assets. Id. at 491. The Second Circuit affirmed the district court's order directing the public disclosure of Biaggi's testimony based solely on his waiver, finding that "no matter how much, or how legitimately, the public may want to know whether a candidate for high public office has invoked the privilege against self-incrimination before a grand jury, or has lied about having done so, that interest must generally yield to the larger one of preserving the salutary rule of law embodied in Rule 6(e) of Federal Rules of Criminal Procedure. But that is not this case." Id. at 493 (emphasis added). Maxwell, unlike Biaggi, has preserved her right to grand jury secrecy and vigorously opposes disclosure of the grand jury materials.
+
+Lastly, the Florida case the government cites, CA Florida Holdings a Dave Aronberg, has no precedential value in this jurisdiction and involved a civil suit under Florida public records law, not federal grand jury materials protected under Rule 6(e). See Order Granting Plaintiffs Motion for Reconsideration of the Trial Court's February 29, 2024 Order, CA Florida Holdings, LLC a Dave Aronberg and Abruzzo, 50-2019 CA-014681 (15th Cir. July 1, 2024). It is wholly inapposite.
+
+There is no precedent for unsealing grand jury transcripts in an ongoing matter like Maxwell's case. Accordingly, the government's motion should be denied.
+
+# IV. CONCLUSION
+
+The government's motion to unseal the grand jury materials in this matter should be denied.
+
+Dated: August 5, 2025 Respectfully submitted,
+
+MARICUS/M PLLC 40 N.W. Third Street, PH1 Miami, Florida 33128 Tel: (305) 379.6667 markuslaw.com
+
+By: lei David Oscar Markus David Oscar Markus Florida Bar Number 119318 dmarkus@markuslaw.com
+
+> Melissa Madrigal (MM0200) New York Bar Number 5242433 Florida Bar Number 93241 mmadrigal@markuslaw.com

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842934/EFTA02842934.md

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+20 Cr. 330 (PAE)
+
+-v-
+
+ORDER
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+PAUL A. ENGELMAYER, District Judge:
+
+This Order publicly dockets the five letters submitted yesterday on behalf of victims and other individuals regarding the Government's request to unseal the grand jury materials in this case. See Dkt. 789 (inviting letters from victims regarding Government's motion to unseal); Dkt. 801 (providing logistical instructions for such letters). These letters have been redacted to the extent requested, to respect privacy interests. This Order also attaches the Government's transmittal letter to the Court that contained these letters.
+
+SO ORDERED.
+
+PAUL A. ENGE AY R United States District Judge
+
+Dated: August 6, 2025 New York, New York
+
+### August 6, 2025 Government Letter
+
+![](_page_2_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The Jacob K. Jowls Federal Budding 26 Federal Plaza, 37th Floor New York. New York 10278
+
+August 6, 2025
+
+#### BY HAND
+
+Honorable Paul A. Engelmayer Attention: A.J. Smallman United States District Court Southern District of New York 2201 40 Foley Square New York, NY 10007
+
+> Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE)
+
+
+The Government respectfully submits this letter and its attachments pursuant the Court's order, dated August 5, 2025. (Dkt. 801). The Government has received five submissions, which are enclosed. The following is a list of those submissions and an indication of whether they may be publicly filed with or without redactions.
+
+- 1. Response to Victim Notification Request, dated August 4, 2025, and signed by John Scarola, Esq.: The submission does not contain any identifying information for victims and therefore it may be filed without redactions.
+- 2. Letter dated August 5, 2025, and signed by Sigrid McCawley, Esq.: Counsel informed the Government that they are not seeking any redactions to this submission and therefore it may be filed without redactions.
+- 3. Letter dated August 5, 2025, and signed by M, Esq.: Counsel informed the Government that they are not seeking any redactions to this submission and therefore it may be filed without redactions.
+- 4. Letter dated Aiii,2025, which is unsigned but was submitted to the Government by Esq.: The submission does not contain any identifying information for victims and therefore it may be filed without redactions.
+- 5. Letter dated August 5, 2025, and signed by Neil S. Binder, Esq.: Counsel provided two versions of the letter—one for filing under seal and the other with redactions for public filing.
+
+Hon. Paul A. Engelmayer, U.S.D.J.
+
+August 6, 2025
+
+
+
+
+JAY CLAYTON
+
+United States Attorney for the Southern District of New York
+
+by: /s/ Jav Clayton Jay Clayton
+
+### Tab 1
+
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+United States of America
+
+v. Case No. 1:20-cr-330 (AJN)
+
+Ghislaine Maxwell,
+
+Defendant.
+
+#### RESPONSE TO VICTIM NOTIFICATION REQUEST
+
+The undersigned is counsel to multiple victims of the criminal conduct of Jeffrey Epstein addressed in Grand Jury proceedings sought by Motion of the U.S. Department of Justice to be unsealed. Pursuant to the Court's direction by order of July 22,2025, the position of our clients in response to the Motion is expressed as follows:
+
+We are in full agreement with the public disclosure of the grand jury transcripts, and further state that all Epstein-related information and documents in the possession and control of law enforcement, prosecutorial and other government agents and entities should be fully disclosed. All disclosures should be subject only to the condition that the identity and privacy rights of all victims be scrupulously preserved. This request for disclosure includes but is not limited to the complete transcripts of all interviews and depositions that have been or may be conducted with Ghislaine Maxwell.
+
+Dated: August 4, 2025
+
+Respectfully submitted, /s/ John Scarola John Scarola, Esq. Florida Bar No. 169440 \_scarolateam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Telephone
+
+# Tab 2
+
+![](_page_7_Picture_1.jpeg)
+
+Sigrid McCawley Telephone: (954) 3774223 Email: smccawley®bsfllp.com
+
+
+Hon. Richard M. Berman U.S. District Court for the Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007
+
+Hon. Paul A. Engelmayer U.S. District Court of the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007
+
+Re: Unsealing of Grand Jury Transcripts in U.S. v. Epstein, 19-cr-490 (RMB) and U.S. v. Maxwell, 20-cr-330 (PAE)
+
+Dear Judges Berman and Engelmayer,
+
+We write on behalf of in response to the belated notice that we received from the Department of Justice on July 25, 2025, advising that the Court is seeking letters on behalf of victims setting out their positions on the proposed disclosures of Jeffrey Epstein's and Ghislaine Maxwell's grand jury transcripts.'
+
+By the Government's admission, "over one thousand victims" suffered from Epstein's and Maxwell's actions. To date, however, the combined forces of our country's law enforcement agencies have only ever arrested these two individuals in connection with crimes committed against countless young women and girls, and the Government's recent suggestion that no further criminal investigations are forthcoming is a cowardly abdication of its duties to protect and serve.2
+
+is a survivor of Epstein's and Maxwell's crimes and testified at Maxwell's trial. While the undersigned counsel has at various times, represented hundreds of victims of Epstein and Maxwell aside from IMM. the Department of Justice's notice did not identify the specific victims whose names, likenesses, or information may be subject to disclosure.
+
+{sup}`2` Of those two, Epstein escaped justice through his apparent suicide, and Maxwell is now, to the victims' horror, herself attempting to escape justice by negotiating for herself a potential pardon
+
+It is obviously impossible for two people to conduct a decades-long sex-trafficking enterprise involving thousands of victims without other individuals who participated in and facilitated these unspeakable atrocities.
+
+The recent controversy surrounding the Government's decision to withhold information concerning Epstein's and Maxwell's crimes has largely ignored the victims' perspective. is thankful for the Court's invitations to state the victims' positions, and supports the unsealing of the grand jury transcripts, as well as the accompanying grand jury exhibits, with redactions only as necessary to protect victims' names, likenesses, and identifying information. Transparency is critical to justice, and the public has a legitimate interest in understanding the full scope of Epstein's and Maxwell's crimes, particularly where those actions caused lasting harm to others. While it was not the victims' decision to seek disclosure of the grand jury transcripts alone (as opposed to the much larger volume of information available in the "more than 300 gigabytes of data and physical evidence" in the Government's possession that should be disclosed as well), the instant motion for unsealing will help expose the magnitude and abhorrence of Epstein's and Maxwell's crimes.
+
+In this case that involved a decades-long, systematic criminal scheme that shocked the conscience of the public, caused lasting harm to survivors, and raised credible concerns about the failures of institutional accountability, there is an especially compelling interest in transparency. Unsealing the grand jury transcripts will illuminate the scope of Epstein's and Maxwell's abuse, provide additional insight into those who enabled his abuse, and bring light to how these crimes were investigated and prosecuted. While grand jury secrecy serves important purposes, it is not absolute and under these circumstances the balance tilts in favor of disclosure.
+
+#### 1. Given the Magnitude and Abhorrence of Epstein's and Maxwell's Crimes, the Unsealing of the Grand Jury Transcripts Is Appropriate.
+
+The Second Circuit has recognized that there are special circumstances when the release of grand jury records is appropriate based on the courts' supervisory authority over the grand juries they empanel and that the trial court has "wide discretion ... in evaluating whether disclosure is appropriate." In re Petition of Craig, 131 F.3d 99,102,104 (2d Cir. 1997). In Craig, the Second Circuit outlined a non-exclusive list of factors that a trial court may consider when deciding whether "special circumstances warrant the release of grand jury transcripts. Id. at 106. We join the Government's arguments for unsealing under the Craig factors, Epstein Dkt No. 66, at 3-7. Two factors warrant additional discussion in light of the victims' position in favor of unsealing.
+
+or commutation of her sentence. The victims of her crimes unequivocally object to any potential leniency that the Government may be considering offering Maxwell, a convicted sex trafficker.
+
+#### A. Why Disclosure Is Being Sought in Particular Case
+
+Grand jury secrecy may serve legitimate purposes in ordinary cases, but this is no ordinary case. In addition to the public interest that the Government identifies, Epstein Dkt. No. 66 at 4-5, disclosure of the grand jury transcripts in this case serves the interest of Epstein's and Maxwell's victims in bringing light to Epstein's and Maxwell's horrific crimes. This transparency and accountability is a form of justice. Epstein is the world's most notorious sex offender, and his crimes span decades, with thousands of victims. Epstein was a calculated predator who preyed on minors and young women using wealth, deceit, and manipulation. Maxwell, his righthand woman, played a central role in recruiting, grooming, and trafficking Epstein's victims, oftentimes participating in the abuse. Her participation, and the complicity and participation of others, enabled Epstein to conduct a decades-long sex-trafficking scheme.
+
+Given the magnitude and abhorrence of Epstein and Maxwell's crimes, unsealing the grand jury transcripts is not just appropriate, it is necessary to understand the full scope of the abuse and those who enabled it. For years, victims of Epstein's and Maxwell's crimes have been silenced, fearful of the repercussions of exposing the many powerful individuals in Epstein's network, many of whom have not yet been named or investigated. Unsealing the grand jury transcripts would allow additional important information to emerge without requiring the victims to expose themselves to the same ridicule, retaliation, and humiliation they would face if they were the ones to expose such information. The Government itself acknowledged that there are "over one thousand victims," 3 yet only a small fraction—approximately one-fifth—have received compensation, underscoring the continuing lack of full accountability for Epstein, Maxwell, and their co-conspirators. The interests of the victims should therefore weigh in favor of disclosure. See Matter of Aiani v. Donovan, 98 A.D.3d 972, 974 (2d Dep't 2012) (ordering disclosure of banking records requested in connection with grand jury proceedings based on the interests of the victims).
+
+#### B. Whether Witnesses to the Grand Jury Transcripts Who Might Be Affected by Disclosure Are Still Alive
+
+This factor considers whether individuals who may be affected by the disclosure of grand jury materials may be adversely impacted by unsealing. This case presents a rare and compelling circumstance where the victims seek transparency, not secrecy. In In re National Security Archive, for example, where the proceedings held substantial historical importance and the living witnesses did not express any objection to the release, the Court found that the release of grand jury testimony was appropriate. 2008 WL 8985358, at \*1-2 (S.D.N.Y. Aug. 26, 2008). The victims represented by the undersigned counsel who are still alive do not just passively support unsealing, but
+
+{sup}`3` See U.S. Dep't of Justice, Federal Bureau of Investigation, Memorandum (July 6, 2025), https://www.justice.goviopa/media/1407001/dl?inline.
+
+affirmatively support unsealing, subject to appropriate redactions to protect their personal privacy. Their consent to disclosure should weigh in favor of unsealing under this factor. Further, because the Government intends to redact the names and identifying information of the victims, there is no risk that the privacy of the victims will be jeopardized. In re Kidder, 800 F. Supp. 2d 42, 50 (D.D.C. 2011) (procedures for reviewing transcripts to protect named individuals as needed "allay any remaining privacy concerns").
+
+#### 2. The Court Should Assess the Appropriateness of the Redactions.
+
+The grand jury transcripts should be released subject to narrowly tailored redactions of the names, likenesses, and identifying information of the victims. The Court should not, however, rubber stamp redactions to withhold from the public "information related to third parties who neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell were charged," Epstein Dkt. No. 66 at 7. Any effort to redact third party names smacks of a cover up. The Government does not elaborate on what protocol it is using to redact other "third party" names or which types of individuals it seeks to protect in this way. To the extent the Government for some reason seeks to redact the names of other Epstein and Maxwell affiliates on the basis that these individuals "neither have been charged or alleged to be involved" in their crimes, the Court should exercise its independent author to ensure that any redactions are tailored to serve compelling interests. See generally v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (even if materials are not considered judicial documents to which a presumption of public access applies, "a court must still articulate specific and substantial reasons for sealing such material").
+
+#### A. Redactions of the Names and Identifying Information of the Victims Is Appropriate.
+
+The privacy interests of and other victims (as victims of sex abuse and human trafficking) are strong. In v. Maxwell, Judge Preska repeatedly recognized the "gravity of the privacy interests" of "victims of Jeffrey Epstein's sexual abuse." v. Maxwell, 2020 U.S. Dist. LEXIS 221599, at \*16 (S.D.N.Y. Nov. 25, 2020). The Court explained that "[t]hose interests are particularly acute given that the psychological and emotional wellbeing of survivors of alleged sexual assaults may be implicated by such a broad disclosure." v. Dershowitz, 2020 WL 5439623, at \*2 (S.D.N.Y. Sept. 9, 2020). And "[t]hose interests weigh no less heavily" where "it is law enforcement seeking modification of the protective order instead of a, litigant." v. Maxwell, 2020 U.S. Dist. LEXIS 221599, at \*16. In Doe 1 v. JP Chase Bank N.A., Judge Rakoff recently found that the privacy interest of a victim of Epstein justified sealing because "[p]rotecting the identity of sexual assault survivors and the details of their assaults is traditionally considered private and has been widely recognized as a compelling reason to limit public access to [even] judicial documents." 742 F. Supp. 3d 387, 397 (S.D.N.Y.
+
+2024). Thus, and other victims' privacy interests as victims of Epstein and Maxwell weigh heavily in favor of the redactions of the victims' names and identifying information.
+
+#### B. Redactions of Names and Information Relating to Epstein and Maxwell's Co-Conspirators Are Improper.
+
+The Government's original motion refers to a July 6, 2025 Memorandum that concluded that no evidence could predicate an investigation into uncharged third parties associated with Epstein's and Maxwell's criminal scheme. Epstein Dkt. No. 61 at 1-2. The Government purports to seek the unsealing of the grand jury transcripts to provide transparency for the public into the conclusions reached by the Memorandum. Id. To be clear, we do not agree that there is insufficient evidence to support investigations into third parties who enabled Epstein's and Maxwell's crimes and participated in them. Numerous individuals have yet to be investigated and several civil cases have been filed addressing other individuals' central involvement with Epstein's and Maxwell's sex trafficking.
+
+As the Court acknowledged, there are "over one thousand victims" of Epstein's and Maxwell's crimes. Epstein Dkt. 63 at 4. Less than one-fifth of these victims have been compensated for the crimes committed against them, either through the now-closed Epstein Victims Compensation Fund or otherwise. To rectify this, there have been numerous civil cases filed that address third parties' central involvement with Epstein and Maxwell's sex-trafficking crimes. See Doe 1 v. .11' Chase Bank NA., Case No. 22-cv-10019 (S.D.N.Y.), Doe I v. Deutsche Bank Aktiengesellschaft, Case No. 22-cv-10018 (S.D.N.Y.); Doe 3 v. Indyke, Case No. 24-cv-01204 (S.D.N.Y.). To the extent any of Epstein's and Maxwell's enablers and coconspirators who have thus far evaded accountability are implicated by the grand jury transcripts, their identities should not be shielded from the public. Though "[t]he privacy interests of innocent third parties" like the victims should be redacted, see Gardner v. Newsday, Inc., 895 F.2d 74, 79 (2d Cir. 1990), there should be no similar protection for those third parties accused of wrongdoing.
+
+\*\*\*
+
+strongly supports the release of Epstein's and Maxwell's grand jury transcripts, subject to appropriate redactions of the victims' names and identifying information. Unsealing the grand jury transcripts serves the interests of transparency, accountability, and restorative justice.
+
+
+Is/ Siurid S. McCawley Sigrid S. McCawley
+
+Counsel for
+
+### Tab 3
+
+![](_page_13_Picture_1.jpeg)
+
+Florida Office
+
+425 North Andrews Avenue Suite 2 Fon Lauderdale, FL 33301
+
+Telephone (954)524-2820 Fax (954)524-2822 info@cvlIcom Brad@cvif.com Brittanp@cvlticom
+
+
+SDNY Victim and Witncss Coordinator United States Attorney's Office 26 Federal Plaza, 37th Floor New York, New York 1-866-874-8900 Via Final ISANYS.Enstch tit axwellViciimsOusdoi.gm New York Office
+
+ByApporaament 04 ,
+
+#### RE: Crime Victims' Rights Act Implications Regarding Unse'ling of Grand Jury Materials in Maxwell Proceedings
+
+Case: USA v Maxwell Case No.: 1:20-cr-00330 (PAE)
+
+
+We represent numerous survivors of Jeffrey Epstein and Ghislaine Maxwell, including individuals whose names and identifying information appear in the subject materials and one woman who testified at Ghislaine Maxwell's criminal trial. Many of these victims placed inunense personal and emotional trust in the federal justice system, with the belief that the conviction of Ms. Maxwell finally represented a measure of accountability. Most view that conviction as the only justice they ever received from the criminal justice system.
+
+In that vein, we write to address the Department of Justice's request to unseal grand jury materials and to respectfully urge the Court to administer any disclosure in a 'rimier that fully honors the victims' rights under the Crime Victims' Rights Act ("CVRAI, 18 U.S.C. § 3771, the enduring interests protected by Federal Rule of Criminal Procedure 6(e), and Eleventh Circuit precedent.
+
+#### I. Victims' CVRA Rights Are Directly Implicated and Must Be Considered in Context— Not in a Vacuum
+
+The CVRA guarantees victims:
+
+- The right to be reasonably protected from the accused (S 3771(4(1));
+
+Honorable Paul A. Engelmayer  
+Case No.: 1:20-cr-00330 (PAE)  
+Page 2
+
+---
+
+- The right to be heard at any public proceeding involving release, parole, or sentencing (§ 3771(a)(3));
+- The right to confer with the attorney for the Government (§ 3771(a)(5)); and,
+- The right to be treated with fairness and respect for dignity and privacy (§ 3771(a)(8)).
+
+*See also Kenna v. U.S. Dist. Court*, 435 F.3d 1011, 1016–17 (9th Cir. 2006) (fairness and dignity are substantive, enforceable rights); *In re* [REDACTED], 527 F.3d 391, 394–95 (5th Cir. 2008) (government must confer with victims before making consequential case decisions); *In re* [REDACTED], 994 F.3d 1244 (11th Cir. 2021) (en banc) (confirming that CVRA protections are fully attached post-conviction).
+
+Crucially, the victims' position regarding unsealing cannot be viewed in isolation as multiple developments are occurring simultaneously:
+
+- **Maxwell's New Platform and Public Legitimization:** Despite being convicted on federal sex trafficking charges, Maxwell has been given a public platform to speak with highly influential individuals such as Deputy Attorney General Todd Blanche, as though she were a credible authority. That is particularly jarring given that she was charged with multiple sex-trafficking offenses and two counts of perjury arising from civil depositions on these very subjects. To be clear, we do not take issue with Mr. Blanche meeting with Ms. Maxwell, seemingly at Maxwell's request, to obtain gratuitous information she wants to provide. However, for survivors who bravely testified, the perception that Ms. Maxwell is being legitimized in public discourse has already resulted in re-traumatization.
+- **Transfer to a Lower-Security Facility:** Maxwell's recent move to a lower-security prison has further eroded the victims' confidence that their safety and dignity are priorities. The transfer was made without prior notice to the victims, without opportunity to object, and without explanation—actions they see as extraordinarily insensitive and suggestive of ulterior purposes.
+- **Lack of Consultation on Unsealing:** The government sought the unsealing of grand jury materials before this Court without first conferring with the victims or their counsel, a step required by the CVRA and reinforced by *Doe v. United States*, 08-80736 (S.D. Fla.). That case, litigated pro bono by undersigned counsel for more than a decade, arose precisely because the government previously violated the rights of many of these very same victims. It is especially troubling that, despite the outcome of that litigation, the government has once again proceeded in a manner that disregards the victims' rights—suggesting that the hard-learned lessons of the past have not taken hold. This omission reinforces the perception that the victims are, at best, an afterthought to the current administration.
+- **Concrete Fear of Clemency:** Survivors are acutely concerned that unsealing, coupled with the transfer and Ms. Maxwell's public platform, may be a prelude to clemency. The risk of a pardon or commutation exacerbates safety concerns in derogation of § 3771(a)(1), and threatens severe psychological harm, including triggering trauma responses. For
+
+Honorable Paul A. Engelmayer Case No.: 1:20-cr-00330 (PAE) Page 3
+
+> some, the Maxwell conviction is the only meaningful measure of criminal accountability; its erosion would be devastating.'
+
+Of significant concern, the same government that failed to provide notice to die victims before moving this Court to unseal the grand jury materials is now the govenunent representing to this Court that it has provided appropriate notice to die victims or their counsel and has conducted a proper review and redaction of the materials it seeks to release. Several clients have contacted us expressing deep anxiety over whether the redactions were in fact adequate. Consequently, we requested yesterday that the government identify which of our clients were referenced to the grand jury. The government responded promptly and provided clarification. However, we have strong reason to believe that additional individuals—whom we also represent—were likely referenced in those materials but were not identified to us by the government.
+
+It remains unclear whether notice was instead provided to prior counsel, whether their omission was a government oversight, whether the government does not consider them to be victims, or whether these individuals were, in fact, not mentioned to die grand jury. Regardless of the explanation, this ambiguity raises a serious issue that must be resolved before any materials are publicly released.
+
+Against this backdrop, any disclosure of grand jury material—especially material that could expose or help identify victims in any way—directly affects the CVRA's fairness, privacy, conferral, and protection guarantees. To ensure those rights are protected, it is essential that the protocol outlined in the relief requested below is adopted by this Court.
+
+#### II. Rule 6(e) and Eleventh Circuit Authority Require Heightened Caution and Narrow Tailoring.
+
+Grand jury secrecy is a "long-established policy" safeguarded by Rule 6(e). Douglas Oil Co. v. Petrol Stops Nw., 441 U.S. 211, 219-23 (1979). Even where disclosure may be considered, the movant must establish a particularized need that outweighs the countervailing interests in secrecy, and any disclosure should be no broader than necessary. Id. at 222-23. The Eleventh Circuit has further held that district courts lack inherent authority to order grand jury disclosure outside the exceptions in Rule 6(e). Pitch v. United States, 953 F.3d 1226, 1237-38 (11th Cir. 2020) (en bane); see also McKeever v. Ban; 920 F.3d 842, 845-46 (D.C. Cir. 2019).
+
+Here, even if the Court were to find a Rule 6(c) path to limited disclosure, victims' CVRA rights and the traditional interests protected by grand jury secrecy converge in favor of extraordinary care: rigorous judicial screening, robust redactions, minimization of any risk of re-identification, and meaningful victim participation before anything is made public. Related privacy provisions reinforce
+
+{sup}`&#`x27; Several victims have already died by suicide, drug overdose, or wider tragic circumstances tied directly to die trauma caused by Epstein and Maxwell. The psychological toll of this abuse is ongoing. A pardon, issued in silence or secrecy, would reignite deep trauma, destabilize the already-fragile healing process of many survivors, and could result in further irreparable harm—including loss of life. It would suggest to victims everywhere that powerful predators are once again above the law.
+
+Honorable Paul A. Engelmayer Case No.: I :20-cr-00330 (PAE) Page 4
+
+this approach. See, e.g., 18 U.S.C. § 3509(d)(2) (authorizing protective orders to shield child-victims' identities and "other information contenting a child"); Fed. R. Crim. P. 49.1 (privacy redactions). Many Epstein/Maxwell victims were minors at the time of the abuse; even for those now adults, § 377 HaR8,) and the Court's protective authority warrant safeguards that functionally align with § 3509(d) principles.
+
+#### III. Requested Relief
+
+In light of the foregoing, the victims respectfully request that the Court:
+
+- I) Require Conferral and Notice (CVRA §§ 3771(4(5), (c)(1)): Direct the Government to confer with victims' counsel and provide reasonable notice and an opportunity to be heard before any ruling on unsealing or public release of grand jury materials.
+- 2) Judicial In Camera Review: Conduct a comprehensive in camera review of the grand jury materials to determine whether the proponent has shown a Rule 6(e)-compliant basis for any disclosure and, if so, the narrowest scope of disclosure consistent with Douglas Oil
+- 3) Victims' Counsel Pre-Release Review (Under Protective Order): Permit designated victims' counsel to review the govenunent's proposed redactions and any index of materials under a strict protective order, to allow victims' counsel to identify and prevent: (a) direct identifiers,
+  - (b) combinations of data points that could reasonably lead to re-identification or harassment of victims, and (c) to propose all additional redactions necessary.
+- 4) Dispute Resolution before Unsealing or Release: If the government does not agree with additional proposed redactions from victims' counsel, provide victims' counsel die opportunity to be heard on any dispute before ruling on unsealing or public release.
+- 5) Defer or Deny Without Prejudice if Safeguards Cannot Be Assured: If adequate safeguards cannot be implemented consistent with Rule 6(e), fittA and the CVRA, deny disclosure without prejudice.
+
+### IV. Conclusion
+
+The survivors support transparency when it can be achieved without sacrificing their safety, privacy, or dignity. But transparency cannot come at the expense of the very people whom die justice system is sworn to protect—particularly amid contemporaneous events that inaguilV risk and trauma: the public platfomUng of Ms. Maxwell as a purportedly credible commentator despite her sex-trafficking conviction and perjury charges, her transfer to lower-security custody, a government request to unseal filed without conferral, and the looming specter of clemency.
+
+These survivors have already endured profound violations of their rights and dignity, both during the years of Epstein's abuse and in the years following. To now compound their trauma by sidelining
+
+Honorable Paul A. Engelmayer Case No.: 1:20-cr-00330 (PAE) Page 5
+
+them from critical decisions—especially in this climate of heightened concern—is inconsistent with both the letter and the spirit of the CVRA.
+
+The CVRA, Rule 6(e), and Eleventh Circuit authority all point toward narrow tailoring, maximal privacy protections, and meaningful victim participation before any grand jury material sees daylight We respectfully ask the Court to adopt the safeguards outlined above.
+
+
+Britian
+
+425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Email: brad@cvlf.com brittany®cvlf.com
+
+Paul G. Cassell Utah Appellate Project S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112-0300 Tel: 801-580-6462 Email: pecassell.lawagmail.com (institutional address for identification purpose only, not to imply institutional endorsement)
+
+### Tab 4
+
+
+Hon. Paul A. Engelmayer, U.S.D.J. United States Courthouse 40 Foley Square New York, NY 10007
+
+Hon. Richard M. Berman, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street New York, New York 10007-1312
+
+> Re: United States of America vs. Maxwell. I :20-cr-00330-PAE United States of America vs. Epstein. I :19-cr-00490-RMB
+
+Dear Hon. Judge Engelmayer and Hon. Judge Berman:
+
+I have been taken aback from all the monumental and more recently disheartening things that have taken place between the time Epstein was arrested, the trial that occurred verse Maxwell with Hon. Judge Alison Nathan and now with the letter I write to you today.
+
+This is all very exhausting. As a victim of Jeffrey Epstein and Ghislaine Maxwell and the co-conspirators who were never indicted, you can by to imagine the bewilderment I feel from the the latest happenings. Also, the news that came out today in regards to potentially releasing audio of the interview between Maxwell and Todd Blanche and the various subpoenas.
+
+I think the more concerning thing to me are the subpoena's. Why not subpoena the United States Virgin Island's officials that were working with Epstein to allow him to further his sextrafficking of girls across inter-continental and international lines? "Jeffrey Epstein used the money Black paid him to partially fund his operations in the ViTin Islands." [https:// www.finance.senate.gov/rankinginembers-news/following-new-epstein-revelations-wvdenrenews-demand-for-trump-administration-to-produce-epstein-filesi
+
+Why not subpoena the long-time attorney and accountant Epstein had working by his side? Once again, I just feel like the direction this administration is going is all wrong. AND, what was it that his accountant took from his 7Ist Street NY mansion the day after he "killed himself'? hiws://www.dailymaitco.ukinews/anicle-7498903/Evenuor4Psteins-estate-removed-bagpedophiles-mansion-day-killed-himself:him!
+
+In terms of the audio file that will most likely be redacted once again scrubbing the names of the wealthy and such off the recordings is once again NOT transparency. Unfortunately, the public will never be satisfied and the victims will continue to live this nightmare. I am so confused. Why rewind and go back to the convicted sex trafficker for questioning after all these almost 4
+
+
+years since she was convicted? What was there to ask? What are you conspiring? What is your next step? What is the end game? I ask the United States Government, that so rightfully wants to release the "sealed" documents not all the victims have seen themselves. At least give us notice when you decide to make these decisions, like moving her into a minimum-security prison camp.
+
+I think the victims have a right to hear the audio without redactions. I think the victims should be able to see what the FBI took from his, NYC mansion, FL mansion and USVI private island resort. I think we should be able to see ALL the files. I think any photos or videos of the victims should be given back to them. NOT REVIEWED BY CONGRESS, GROSS!!!!
+
+Will justice ever be served? I question what that would look like to the DOJ, the FBI, because so far we have got nothing, not even an apology, not even the answers we so long for. We all want closure and for this "distraction" to stop! This is some type of psychological games, by keeping the public ignorant. The very fact that something is secret means there is something to hide.
+
+I support the United States Senate Committee on Finance lead by Senator Wyden, "Follow-the-Money" Investigation of Epstein Finances. I thank him and his team for their work, but I request more transparency. I think the victims lawyers should have access to all these findings. We have a right to take legal action against these institutions and/or individuals involved in Epstein's and co-conspirators crimes.
+
+It has been super unfortunate the way the US Government has handle this ordeal. We as victims want answers, but not only us, I think the general public is exhausted also by all of this. The general public cares more about their own personal wellbeing, right? Unfortunately, for us victims, this story will NEVER go away. There will always be an interest in the case of Epstein and Maxwell. Ghislaine's trial was based off of the fact that Jeffrey could never be tried and died by "killing himself'. Why • why will we have to live with this conspiracy for the rest of our lives? Because they keep laboring the truth, scrubbing the data. It is so hurtful and a detriment to the victims to continue disregarding our feeling, our traumas. Please I ask you to consider our well-being first. Please I ask that the true redactions that come first are only for the victims.
+
+Thank you for your time.
+
+### Tab 5
+
+![](_page_22_Picture_1.jpeg)
+
+Neil S. Binder Benda & (I) 212 510 7031 675 Third Avenue, 26th Floor (F) 212 51O 7299
+
+New York, NY 10017 obincler@lindetschwattz conk
+
+#### CONFIDENTIAL - SUBMITTED UNDER SEAL
+
+
+Hon. Paul A. Engelmayer United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007
+
+Re: United Stares v. Maxwell, No. 20-cr-330 (S.D.N.Y.)
+
+
+We represent On the late a ernoon o n y, August 1, t ou different r counse were lorn.by the U.S. Department of Justice ("DOT' or e government") that they are referenced in some capacity in the sealed grand jury materials that are the subject of DOJ's recent motion for unsealin See U.S. Mot. to Unseal Grand Jury Trs., July 18, 2025, Dkt. No. 785. requested from the government information about the context in which are named in these materials in order to inform our arguments regarding the continu sea mg of the grand jury materials. The government has declined to provide us with any information. Absent such information, we cannot respond with specificity to any reference in the record concerning.. Specificity in this context may not be required, however, as Supreme Court precedent an case w in this Circuit make clear what this Court recognized in its July 22, 2025 Order—i.e., that there is "long-established policy [of] maintain[ing] the secrecy of the grand jury proceedings in the federal courts." United States v. Procter & Gamble Co., 356 U.S. 677, 681 (1958); see also In re Grand Jury Investigation of Cuisinarts, Inc., 665 F.2d 24, 28 (2d Cir. 1981) ("This time-honored policy of secrecy has been the most essential, indeed indispensable, characteristic of grand jury proceedings."). Indeed, this requirement of secrecy has been codified in Federal Rule of Criminal Procedure 6(e). While the Second Circuit has recognized that there are certain "special circumstances" outside of Rule 6(e)' that may justify the unsealing of grand jury records, the burden of demonstrating those special circumstances is even greater than the already heavy burden of demonstrating the applicability of one of the exceptions enumerated in Rule 6(e). See In re Petition of Craig, 131 F.3d 99, 106 a 10 (2d Cir. 1997).
+
+<sup>&#</sup>x27; The government does not point to any of the statutory exceptions enumerated in Rule 6(e) to justify the need for disclosure here. instead relying solely on "special circumstances" outside the bounds of those exceptions as articulated in In re Petition of Craig. 131 F.3d 99 (2d Cir. 1997). U.S. Mot. to Unseal Grand Jury Trs. at 3. July 18. 2025, Dkt. No. 785.</p><p>BINDER &<br/>SCHWARTZ</p><p>The government has plainly not met its burden to justify an unsealing in this case.<sup>2</sup> And even if this Court determines that unsealing is warranted despite the high burden required to do so, [redacted] respectfully request that any reference to them or to any information which may be used to identify them be redacted from any public filing. [redacted]</p><p>[redacted] innocent third parties at the time of any allegations contained in the grand jury materials, and any references to them should remain sealed. While we are not aware of the context in which [redacted] are mentioned in the grand jury materials (despite counsel having asked DOJ), the events detailed in the indictment of Ghislaine Maxwell occurred between 1994 and 1997. [redacted]</p><p>Any reference to [redacted] similarly should remain sealed, as they are also innocent third parties and publication of their names in connection with these materials would have the potential to contribute to additional needless and irreparable harm beyond what they have already suffered as a result of this matter. Where, as here, the effect of unsealing grand jury materials would have the potential to harm still-living third parties, the historical interest of the public cannot outweigh the privacy interests in keeping the materials under seal. <i>See In re Application of Newsday, Inc.</i>, 895 F.2d 74, 79–80 (2d Cir. 1990) (emphasizing in the context of a request to unseal a search warrant application that “privacy interests of innocent third parties as well as those of defendants . . . should weigh heavily in a court’s balancing equation” (quoting <i>In re N.Y. Times Co.</i>, 828 F.2d 110, 116 (2d Cir. 1987))); <i>Craig</i>, 131 F.3d at 107 (directing courts assessing requests to unseal grand jury materials to pay particular attention to the request’s timing, given that the passage of time may weigh in favor of disclosure of grand jury materials because it inevitably “brings about the death” of all parties involved).</p><h4>I. The grand jury materials in this case should remain sealed</h4><p>There is a long history of maintaining the secrecy of grand jury proceedings for a reason. The purposes of the secrecy include ensuring the freedom of grand juries in their deliberations and “to protect [the] innocent accused . . .” <i>Procter & Gamble</i>, 356 U.S. at 681 n.6. Beyond protecting innocent parties who are the subject of grand jury investigations, this secrecy also serves to protect witnesses and other innocent nonparties who may be mentioned in grand jury proceedings from any unwarranted association with the crimes alleged therein. Because of the policy and due process rationale behind grand jury secrecy, the permissible bases upon which grand jury materials may be shared are limited to certain exceptions in Rule 6(e)(3). The Second Circuit has recognized limited additional “special circumstances” in which release of grand jury records is appropriate, including historical interest by the public. <i>Craig</i>, 131 F.3d at 102. But in</p><hr/><p><sup>2</sup> The Southern District of Florida recently declined to unseal the grand jury materials pertaining to the government’s investigation into Jeffrey Epstein, which we understand concerns the same or substantially similar facts. Due to a Circuit split, the Southern District of Florida evaluated only the exceptions to grand jury secrecy enumerated in Rule 6(e). Order Den. Pet. to Unseal Grand Jury Trs., <i>In re Grand Jury 5-02 & 07-103</i>, 9:25-mc-80920 (S.D. Fla. July 23, 2025).</p><p block-type='Text'>remain sealed. or t ese reasons. 1 e gran July matena re at • to should</p><p><img src='\_page\_24\_Picture\_1.jpeg'></p><p block-type='Text'>considering whether a special circumstance, such as historical interest by the public, justifies the unsealing of grand jury materials, courts must consider the "countervailing interests in privacy and secrecy." In re Petition of Nail Sec. Archive, 104 F. Supp. 3d 625, 628 (S.D.N.Y. 2015). The timing of the request in comparison to when the grand jury proceedings took place is "one of the most crucial elements" for courts to consider because it relates to the "continued existence and vulnerability o' parties involved in the proceedings, another factor that courts should consider when evaluating the request. Craig, 131 F.3d at 107.3</p><h4>a. The privacy interests justifying disclosure outweigh any historical interest</h4><p block-type='Text'>The government cannot satisfy the high burden of showing that it has met the "special The grand juiy proceedings at issue here took place only within the last • circumstances" required for unsealing of the grand jury materials in this case with respect-Iyears. any, if Inot most, of the relevant witnesses and parties mentioned in the proceedings are still livi</p><p block-type='Text'>remain vulnerable to e potent' negative impact o Nang any a e association wt t e matters at issue in this case made public. The degree of injury that would face from disclosure is difficult to overstate. Given the media frenzy t s accompanied all activity in this case, there is no doubt that the press will scrutinize eve unsealed filing. Publicizing any information in the grand jury materials related to will inflict irre arable harm on them through the very fact of their association wi 1 s case,</p><p block-type='Text'>There is no uestion that the interests in the rivacy and secrecy of innocent third parties and who are still alive today, 'c has in reviewin these materials.</p><p>In Craig. the Second Circuit lists nine "non-exhaustive" factors that a trial court should consider when deciding whether to unseal grand jury materials because of "special circumstances." Id. at 106.</p><p>BINDER &<br/>SCHWARTZ</p><p><b>b. The privacy interests of [REDACTED] outweigh any historical interest justifying disclosure</b></p><p>The same legal analysis applies to the privacy interests of [REDACTED]. While the government has not provided any information about the context in which [REDACTED] are mentioned in the grand jury materials, the potential harm to the privacy interests of these third parties from unsealing of the transcripts is significant.</p><p>This Court and the government are aware of the media appetite for all information related to this case, regardless of whether such information is true or false. [REDACTED]</p><p>[REDACTED] The unsealing of [REDACTED] even if innocuous, will only serve to allow for [REDACTED] at a time when the political attention on this case is perhaps at its most significant. <i>Cf. United States v. Amodeo</i> ("Amodeo II"), 71 F.3d 1044, 1051 (2d Cir. 1995) ("Courts have long declined to allow public access simply to cater to a morbid craving for that which is sensational and impure." (internal quotation marks omitted)). The Court should order that the transcripts remain under seal.</p><p><b>II. If the Court determines that unsealing is warranted despite the weight of precedent, redactions should be appropriately tailored to protect [REDACTED] privacy interests</b></p><p>In the event this Court exercises its discretionary power to unseal these grand jury materials, [REDACTED] respectfully request that its order doing so include detailed guidance to the government on the appropriate redactions that should be applied prior to any unsealing and that [REDACTED] be provided with copies of the materials in which they appear in advance so that they may provide input in order to protect their privacy interests. The government's statement that it will "make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts" does not provide clarity as to what precisely the government intends to redact. Any redactions should include not only [REDACTED] names, but also any other personal identifying information and any surrounding context by which the public may be able to deduce the identities of the individuals being discussed.<sup>5</sup></p><p>\*\*\*\*\*</p><p><sup>5</sup> Failure to redact the surrounding context could allow the substance of redacted testimony to be readily deduced. See Josh Levin, Aaron Mak & Jonathan L. Fischer, <i>We Cracked the Redactions in the Ghislaine</i> [REDACTED] well <i>Deposition</i>, Slate (Oct. 22, 2020, 12:31 PM), <a href="https://slate.com/news-and-politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html">https://slate.com/news-and-politics/2020/10/ghislaine-maxwell-deposition-redactions-epstein-how-to-crack.html</a>.</p><p><img src='\_page\_26\_Picture\_1.jpeg'></p><p block-type='Text'>In a case such as this one, where the press and public have been relentless in their coverage of every detail and lacking in their regard of factual accuracy, even the stray mention of a third-party's name has the potential to cause extreme reputational harm that could never be remedied. The government has not—and cannot—meet its high burden to show why unsealing grand jury materials that mention innocent third parties such as subject of any charges in relation to this case, is merited. And it certa burden with respect to any materials that who were not the cannot meet such a</p><p block-type='Text'>Accordingly, the Court should order that the transcripts remain under seal, or, if e Court orders them unsealed, ensure they are released only with appropriate redactions that go beyond merely proper names but also include any surrounding context that may be used to identify the nonparties, as the privacy interests of a nonparty outweigh the public's historical interest in the disclosure.</p><p block-type='Text'>Respectfully submitted,</p><p block-type='Text'></p><p>Neil S. Binder</p>
+ </body>
+</html></sup>

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842961/EFTA02842961.md

@@ -0,0 +1,49 @@
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x
+
+20 Cr. 330 (PAE)
+
+## DECLARATION OF JEFFREY S. PAGLIUCA AND LAURA A. MENNINGER IN SUPPORT OF MOTION TO WITHDRAW AS CO-COUNSEL
+
+We, JEFFREY S. PAGLIUCA AND LAURA A. MENNINGER, declare as follows:
+
+I. We are partners at the law firm Haddon, & P.C. ("HMF"), cocounsel for defendant Ghislaine Maxwell. We are fully familiar with the facts set forth herein and respectfully submit this declaration pursuant to Local Civil Rule 1.4, Local Criminal Rule 1.1(b) (making Local Civil Rule 1.4 applicable to criminal proceedings), and Local Criminal Rule 1.2, in support of HMF's motion to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.
+
+2. Ms. Maxwell retained HMF to represent her in the above-captioned case. We filed notice of appearances on July 8, 2020. HMF represented Ms. Maxwell at trial and through her sentencing on June 28, 2022.
+
+3. Ms. Maxwell's sentencing concluded her district court proceedings. Ms. Maxwell filed a notice of appeal on July 7, 2022. HMF did not represent Ms. Maxwell in her appellate proceedings.
+
+4. On July 18, 2025, Deputy Attorney General Todd Blanche appeared in this case on behalf of the government and filed a motion to unseal grand jury transcripts.
+
+5. On July 22, 2025, David Markus and Melissa Madrigal of Markus PLLC ("Markus IM'') appeared as counsel of record in this case for Ms. Maxwell.
+
+6. We have spoken with Mr. Markus who has confirmed that Ms. Maxwell has retained Markus to handle the government's unsealing motion and that he is prepared to meet any deadlines imposed by the Court.
+
+7. Mr. Markus has also informed us that he has discussed this motion with Ms. Maxwell and she consents to HMF's withdrawal from this matter.
+
+8. HMF is not asserting any liens in this matter and will share its files with Markus upon request, subject to the conditions imposed by the protective order in this case (Dkt. No. 36).
+
+9. HMF has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.
+
+We declare under penalty of perjury that the foregoing is true and correct.
+
+Dated: August 6, 2025.
+
+Respectfully submitted,
+
+s/Jeffiwy S. Pagliuca
+
+s/ Laura A. Menninger
+
+Jeffrey S. Pagliuca
+
+Laura A. Menninger
+
+945 N. Pennsylvania St.
+
+Denver, CO 80203
+
+Phone: 303-831-7364
+
+Attorneys for Ghislaine Maxwell

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842963/EFTA02842963.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x
+
+20 Cr. 330 (PAE)
+
+## JPROPOSEDI ORDER GRANTING MOTION TO NN ITII k\N
+
+Upon consideration of the Motion to Withdraw, it is HEREBY ORDERED THAT Jeffrey S. Pagliuca and Laura A. Menninger of Haddon, & P.C. are granted leave to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.
+
+Dated: , 2025.
+
+The Honorable Paul A. Engelmayer United States District Judge

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842964/EFTA02842964.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x
+
+20 Cr. 330 (PAE)
+
+## NOTICE OF MOTION TO WITHDRAW
+
+PLEASE TAKE NOTICE that, upon the accompanying Declaration of Jeffrey S. Pagliuca and Laura A. Menninger, we respectfully move this Court for an Order pursuant to Local Rule 1.4 permitting ourselves and Haddon, counsel for defendant Ghislaine Maxwell. & P.C. to withdraw as co-
+
+Dated: August 5, 2025.
+
+Respectfully submitted,
+
+s/ Jeffrey S. Pagliuca
+
+s/ Laura A. Menninger
+
+Jeffrey S. Pagliuca Laura A. Menninger 945 N. Pennsylvania St. Denver, CO 80203 Phone: 303-831-7364
+
+Attorneys for Ghislaine Maxwell

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842965/EFTA02842965.md

@@ -0,0 +1,49 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+20 Cr. 330 (PAE)
+
+-v-
+
+ORDER
+
+GIIISLAINE MAXWELL,
+
+Defendant.
+
+PAUL A. ENGELMAYER, District Judge:
+
+This Order publicly dockets one additional letter, submitted to the Government this afternoon on behalf of a victim in this case, regarding the Government's request to unseal defendant Maxwell's grand jury materials. This letter, which is attached, supplements the five letters submitted yesterday, which the Court previously docketed. See Dkt. 804. The Court understands that no redactions to this letter are needed to protect victims' privacy interests.
+
+SO ORDERED.
+
+Pr iA 6
+
+PAUL A. ENGELMAY United States District Judge
+
+Dated: August 6, 2025 New York, New York
+
+## August 6, 2025 Victim Letter
+
+PANISH SHEA RAVIPUDI LIP
+
+August 6, 2025
+
+## VIA E-MAIL
+
+SDNY Victim and Witness Coordinator United States Attorney's Office 26 Federal Plaza, 37th Floor New York, New York 10278 Email: USANYS.EpsteinMaxwellVictims@usdoj.gov
+
+11111 Santa Monica Boulevard Sub 700 Los hypeles, CA 90025 phone 310.477.1700 Fax 310.477.1699 panish.law
+
+Re: Unsealing of Grand Jury Transcripts in U.S. v. Epstein, 19-cr-490 (RMB) and U.S. v. Maxwell, 20-cr-330 (PAE)
+
+Dear SDNY Victim and Witness Coordinator:
+
+I represented a victim identified as Jane Doe in U.S. v. Maxwell, 20-cr-330. Please be advised I am hereb oinin in the letter submitted to you previously on August 5, 2025 on behalf of victim by her attorney Sigrid McCawley.
+
+With that said, I am strongly opposed to any portions of the grand jury transcripts being released that would in any way identify the victims. If any materials are released, the victims' names and other identifying information should be redacted.
+
+Very truly yours,
+
+Robert S. Glassman

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842968/EFTA02842968.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x UNITED STATES OF AMERICA v. GlitSLAINE MAXWELL, Defendant.
+
+20-CR-330 (PAE)
+
+## ORDER GRANTING MOTION TO WITHDRAW
+
+Upon consideration of the Motion to Withdraw, it is HEREBY ORDERED THAT Jeffrey S. Pagliuca and Laura A. Menninger of Haddon, , P.C. are granted leave to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.
+
+Dated: August 7 , 2025.
+
+Pte( Get The Honorable Paul A. gelm er United States District Judge

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842969/EFTA02842969.md

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+![](_page_0_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The Honorable Richard M. Berman United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007
+
+> Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE)
+
+Dear Judges Berman and Engelmayer:
+
+The Jacob K. davits Federal Building 26 Federal Plaza. 37th Floor New York. New Yore 10278
+
+August 8, 2025
+
+The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, New York 1007
+
+The Government writes respectfully to respond to Judge Engelmayer's Order dated August 5, 2025, and Judge Berman's Order dated August 6, 2025.
+
+In addition to seeking to unseal the grand jury transcripts, the Government moves to unseal the Maxwell and Epstein grand jury exhibits subject to appropriate redactions of victim-related and other personal identifying information. As there are parties whose names appear in the grand jury exhibits but did not appear in the grand jury transcripts, the Government is undertaking to notify such parties to the extent their names appear in grand jury exhibits that were not publicly admitted at the Maxwell trial (and they were not already notified in connection with the request to unseal the grand jury transcripts). The Government respectfully requests to update the Court following those notifications by August 14, 2025, and requests that the Court await that update before unsealing any of the grand jury exhibits, to the extent the Court is otherwise inclined to do so.
+
+In conjunction with this letter, the Government will submit sealed, a parte submissions clarifying which portions of the grand jury exhibits in the Maxwell and Epstein matters have been made public. In making this assessment, the Government has compared the grand jury exhibits against the trial record and exhibits in the Maxwell trial, as well as against any publicly filed civil complaints identified by the Government that were filed by certain victims, as explained in further detail in the Government's sealed, ex parte submissions.
+
+Many civil complaints were filed in federal and state courts on behalf of victims identified solely as "Jane Doe" or by initials that may or may not be the initials of the plaintiffs in those actions, and therefore the Government cannot attribute with certainty to whom the statements or allegations in those anonymized complaints can be attributed. If the Government identifies additional materials on public dockets that make such attribution possible, it promptly will notify the Court.
+
+Hon. Richard M. Berman Hon. Paul A. Engelmayer August 8, 2025 Page 2 of 2
+
+The Government will also today submit to Judge Berman under seal and a pane a version of the Epstein grand jury transcripts that specifically identifies which information in the transcripts is, as far as the Government is aware, publicly available. This approach is in line with that taken by the Government with respect to the Maxwell grand jury transcripts submitted to Judge Engelmayer on August 4, 2025 (20 Cr. 330, Dkt. 800).
+
+As always, the Government is available to answer any questions the Court may have.
+
+Respectfully submitted,
+
+PAMELA J. BONDI United States Attorney General
+
+TODD BLANCHE Deputy United States Attorney General United States Department of Justice
+
+/s/ Jav Clayton
+
+JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278

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marker2-fixhub/court-us-v-maxwell-cr/EFTA02842971/EFTA02842971.md

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+20 Cr. 330 (PAE)
+
+-v-
+
+OPINION & ORDER
+
+GHISLAINE MAXWELL,
+
+Defendant.
+
+PAUL A. ENGELMAYER, District Judge:
+
+On December 29, 2021, a jury convicted defendant Ghislaine Maxwell of five felonies involving the sexual abuse of young girls that she and the notorious pedophile Jeffrey Epstein committed between 1994 and 2004. This decision resolves the Government's July 18, 2025 motion to unseal grand jury transcripts and exhibits in Maxwell's case, subject to redactions aimed at protecting victim confidentiality. Dkt. 785; see also Dkt. 808. For the reasons that follow, the Court denies the motion.'
+
+# I. Background to the Motion to Unseal
+
+# A. Indictments
+
+In late November 2018, prompted by investigative journalism, the United States Attorney in this District opened an investigation into Epstein and his co-conspirators. On July 2, 2019, a grand jury returned an indictment that charged Epstein with participating in a sex trafficking conspiracy, in violation of 18 U.S.C. § 1591(a) and (b).2 On July 6, 2019, Epstein was arrested.
+
+A motion seeking, on similar terms, the unsealing of grand jury materials in Epstein's case is pending before the Hon. Richard M. Berman. See United States v. Epstein, 19 Cr. 490 (RMB) (S.D.N.Y. July 18, 2025), Dkt. 61.
+
+{sup}`2` See United States v. Epstein, 19 Cr. 490 (RMB) (S.D.N.Y. July 2, 2019), Dkt. 2.
+
+On August 10, 2019, Epstein committed suicide while in pretrial custody at the Metropolitan Correctional Center ("MCC"). See generally Dkt. 670 at 3-4; Dkt. 785 at 2.
+
+On June 29, 2020, a grand jury in this District returned a six-count indictment against Maxwell, alleging that she had facilitated and participated in Epstein's sexual abuse of multiple minor girls. It charged her with conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticement of a minor to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to transport minors with intent to engage in illegal sexual activity, in violation of 18 U.S.C. § 371; transportation of a minor with intent to engage in illegal sexual activity, in violation of 18 U.S.C. §§ 2423(a) and 2; and, in two counts, perjury, in violation of 18 U.S.C. § 1623. See Dkt. 1 ("Initial Indictment"). It based these charges on Maxwell's conduct with respect to three minor victims, whom the Government identified pseudonymously. On July 8, 2020, the grand jury returned a superseding indictment that made ministerial corrections. Dkt. 17 ("S 1 Indictment"). On March 29, 2021, a different grand jury in this District returned a second superseding indictment. It added two counts, based on a fourth minor victim, to whom it also referred pseudonymously. One charged a sex trafficking conspiracy, in violation of 18 U.S.C. § 371; the other charged sex trafficking of a minor, in violation of 18 U.S.C. §§ 159I(a), (bX2), and 2. See Dkt. 187 ("S2 Indictment"). The S2 Indictment also broadened the time period of the sexual abuse crimes, originally alleged to span 1994 to 1997, to span 1994 to 2004.
+
+# B. Trial
+
+Trial commenced on November 29, 2021, before the Honorable Alison J. Nathan, to whom this case was then assigned, and a jury, on six counts in the S2 Indictment—all but the two perjury counts.; It ended on December 29, 2021, with Maxwell's conviction on five of the six counts and her acquittal on the substantive enticement count.
+
+The evidence adduced at trial is well-summarized in Judge Nathan's post-trial decision denying Maxwell's post-trial motions, including under Federal Rule of Criminal Procedure 29 for a judgment of acquittal, Dkt. 657; in the Government's brief in Maxwell's appeal, see United States v. Maxwell, No. 22-1426 (2d Cir. June 29, 2023), Dkt. 79; and in the Second Circuit's decision in that appeal, see United States v. Maxwell, 118 F.4th 256 (2d Cir. 2024).
+
+In brief, the Government's evidence included the testimony of four women who described the sexual abuse they had suffered, as girls, at the hands of Epstein and Maxwell; the testimony of individuals who worked for Epstein and Maxwell; the testimony of law enforcement officials; corroborating physical evidence, including photographs of and evidence recovered from searches of Epstein's residences, and Epstein's and Maxwell's black address book; and other corroborating records, such as flight logs of Epstein's private planes and FedEx records.
+
+The trial evidence focused on six girls, including the four testifying victims, who suffered abusive sexual contact as a result of Maxwell's criminal actions: Jane, Kate, Annie, Carolyn, Virginia, and Melissa. It established that Maxwell had been instrumental in an approximately decade-long scheme with Epstein to entice, groom, transport, and traffic numerous young women and underage girls to engage in sexual activity with Epstein. Maxwell helped identify vulnerable girls for abuse, targeting those who faced difficult family circumstances, including
+
+{sup}`3` On April 16, 2021, Judge Nathan granted Maxwell's motion to sever the perjury charges. Dkt. 207. After Maxwell's sentencing, the Government moved to dismiss these counts, in light of victims' interests in closure and avoiding the trauma of testifying again. Judge Nathan granted that motion. See Dkt. 670 at 5 n.1; Dkt. 737 at 99.
+
+financial hardship, substance use disorders, and prior sexual abuse. Maxwell purported to befriend the girls to gain their trust and create the illusion of friendship and responsible adult supervision, while isolating them from others. She then manipulated that trust to normalize sexual abuse by Epstein and herself, often through the pretext of giving Epstein "massages." Maxwell personally participated in acts of sexual abuse, including, for example, instructing then-14-year-old Jane how to touch Epstein's penis during a "massage," and touching Jane's breasts herself. Maxwell and Epstein also paid young girls hundreds of dollars of cash in exchange for meeting Epstein to be sexually abused. Once a girl was introduced to these sexualized massages, she was offered more money if she brought other girls to engage in sexualized massages. Maxwell also fostered a culture of silence at Epstein's various households where sexual abuse occurred, directing employees to "see nothing, hear nothing, say nothing."
+
+# C. Post-Trial Motions
+
+On January 19, 2022, Maxwell moved for a new trial under Federal Rule of Criminal Procedure 33, based on a juror's provision of inaccurate information during jury deliberations. Dkt. 580. On April 1, 2022, after an evidentiary hearing, Judge Nathan denied that motion. Dkt. 653.
+
+On February 11, 2022, Maxwell made other pretrial motions, under Rules 29 and 33. Dkt. 600. On April 29, 2022, Judge Nathan denied all but one of these motions. In the motion she granted, Judge Nathan found that the three conspiracy counts were multiplicitous, and therefore entered judgment on only one of them. Dkt. 657.
+
+## D. Sentencing
+
+Sentencing was held on June 28, 2022. The Government sought a sentence of at least 360 months' imprisonment. Dkt. 670 at 53. The defense sought a sentence below the Guidelines range (188-235 months) calculated by Judge Nathan. Dkt. 737 at 84. Eight victims submitted victim impact statements. Dkt. 686.
+
+Judge Nathan imposed an above-Guidelines sentence of 240 months' imprisonment. Dkt. 737 at 96. Maxwell, she stated, had "directly[,) repeatedly, and over the course of many years participated in a horrific scheme to entice, transport, and traffic underage girls, some as young as 14, for sexual abuse by and with Jeffrey Epstein." Id. at 89. As an example, she noted, after Carolyn had confided in Maxwell her personal history of having been raped and molested by her grandfather starting at a very young age, Maxwell used that knowledge to continue the "cycle of sexual abuse," inducing Carolyn to give Epstein "sexualized massages" for "years," and by herself touching Carolyn's breasts when Carolyn was 14 years old. Id. at 90-91. Judge Nathan also noted that Maxwell had repeatedly deflected blame and lied about her offenses, including in a civil deposition and to Pretrial Services and the Court. Id. at 95.4
+
+## E. Appeal
+
+On February 28, 2023, Maxwell appealed her conviction and sentence. United States v. Maxwell, No. 22-1426 (2d Cir. Feb. 28, 2023), Dkt. 59. The Second Circuit affirmed. It upheld Judge Nathan's (1) holding that a 2007 non-prosecution agreement between Epstein and the U.S. Attorney's Office for the Southern District of Florida did not bar Maxwell's prosecution in this District; (2) holding that the S2 Indictment had been timely filed; (3) denial of Maxwell's Rule 33 motion based on juror misconduct; (4) response to a jury note, which Maxwell had argued resulted in a constructive amendment of or prejudicial variance from the S2 Indictment; and (5) sentence as procedurally reasonable. United States v. Maxwell, 118 F.4th 256, 270 (2d Cir.
+
+Judge Nathan also sentenced Maxwell to a post-imprisonment term of five years' supervised release and to pay a \$750,000 fine (the maximum allowable).
+
+2024). On November 25, 2024, the Second Circuit denied Maxwell's petition for rehearing.
+
+United States v. Maxwell, No. 22-1426 (2d Cir. Nov. 25, 2024), Dkt. 120.
+
+On April 10, 2025, Maxwell petitioned for a writ of certiorari before the Supreme Court. Her petition argues that Epstein's non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida barred her prosecution in this District. See United States v. Maxwell, No. 24-1073 (S. Ct. Apr. 10, 2025). On July 14, 2025, the Government opposed the petition. On July 28, 2025, Maxwell replied. As of this decision, the petition remains pending.
+
+# F. DOD's Recent Statements Regarding the Disclosure of Epstein Records
+
+On February 27, 2025, the Department of Justice ("DOJ") issued a press release. It stated that the Attorney General ("AG") and Federal Bureau of Investigation ("FBI") had declassified and were publicly releasing files relating to Epstein's exploitation of more than 250 girls. Quoting the AG and the FBI Director, the press release stated:
+
+"This [DOJ] is following through on President Trump's commitment to transparency and lifting the veil on the disgusting actions of Jeffrey Epstein and his co-conspirators," said Attorney General Pamela Bondi. "The first phase of files released today sheds light on Epstein's extensive network and begins to provide the public with long overdue accountability."
+
+"The FBI is entering a new era—one that will be defined by integrity, accountability, and the unwavering pursuit of justice," said FBI Director Kash Patel. "There will be no cover-ups, no missing documents, and no left unturned—and anyone from the prior or current Bureau who undermines this will be swiftly pursued. If there are gaps, we will find them. If records have been hidden, we will uncover them. And we will bring everything we find to the DOJ to be fully assessed and transparently disseminated to the American people as it should be.
+
+U.S. Dep't of Just., Attorney General Pamela Bondi Releases First Phase of Declassified Epstein Files (Feb. 27, 2025), https://www.justice.gov/opepriattorney-general-pamela-bondi-releasesfirst-phase-declassified-epstein-files [https://perma.cc/H2QZ-WZCV].5
+
+{sup}`\$` The released documents are described and accessible on the DOD's website.
+
+In the same press release, the DOJ quoted a letter from the AG to the FBI Director, stating that the AG had just learned that the FBI possessed "thousands of pages of documents related to the investigation and indictment of Epstein." The AG's letter continued:
+
+By 8:00 a.m. tomorrow, February 28, the FBI will deliver the full and complete Epstein files to my office, including all records, documents, audio and video recordings, and materials related to Jeffrey Epstein and his clients, regardless of how such information was obtained. There will be no withholdings or limitations to my or your access. The [DOJ] will ensure that any public disclosure of these files will be done in a manner to protect the privacy of victims and in accordance with law, as I have done my entire career as a prosecutor....
+
+I appreciate your immediate attention to this important matter. I know that we are both committed to transparency for the American people, and I look forward to continuing to work with you to serve our President and our country.
+
+Id.
+
+On July 6, 2025, the DOJ and the FBI issued another memorandum regarding Epstein. It stated, in part:
+
+As part of our commitment to transparency, the [DOJ] and the [FBI] have conducted an exhaustive review of investigative holdings relating to Jeffrey Epstein. To ensure that the review was thorough, the FBI conducted digital searches of its databases, hard drives, and network drives as well as physical searches of squad areas, locked cabinets, desks, closets, and other areas where responsive material may have been stored. These searches uncovered a significant amount of material, including more than 300 gigabytes of data and physical evidence.
+
+The files relating to Epstein include a large volume of images of Epstein, images and videos of victims who are either minors or appear to be minors, and over ten thousand downloaded videos and images of illegal child sex abuse material and other pornography.... Only a fraction of this material would have been aired publicly had Epstein gone to trial, as the seal served only to protect victims and did not expose any additional third-parties to allegations of illegal wrongdoing. Through this review, we found no basis to revisit the disclosure of those materials and will not permit the release of child pornography.
+
+This systematic review revealed no incriminating "client list." There was also no credible evidence found that Epstein blackmailed prominent individuals as part of his actions. We did not uncover evidence that could predicate an investigation against uncharged third parties....
+
+One of our highest priorities is combatting child exploitation and bringing justice to victims. Perpetuating unfounded theories about Epstein serves neither of those ends.
+
+To that end, while we have labored to provide the public with maximum information regarding Epstein and ensured examination of any evidence in the government's possession, it is the determination of the Department of Justice and the Federal Bureau of Investigation that no further disclosure would be appropriate or warranted.
+
+U.S. Dep't of Just., Untitled Memo (July 2025), https://www.justice.gov/opa/media/1407001 /dl?inline, at 1. The memorandum included a hyperlink to video footage from Epstein's housing unit, which, it stated, supported the FBI's investigative conclusion that Epstein had committed suicide in his cell at the MCC on August 10, 2019. Id. at 2.
+
+Ensuing news accounts reported public and congressional dissatisfaction with the July 6, 2025 memorandum, and calls for the release of records held by the DOJ and FBI regarding their investigation into Epstein.'
+
+{sup}`6` See, e.g., et al., Rift Erupts Among Justice, FBI Leaders Over Epstein Memo, Sources Say, Wash. Post (July II, 2025), https://www.washingtonpost.com/national-security/ 2025/07/1 Utrump-bondi-patel-bongino-epstein-files/; Sadie Gunman & Alex Leary, Top Trump Officials Split Over Epstein Investigation Conclusion, Wall St. J. (July 11, 2025, 4:38 PM), https://vvww.wsj.com/politics/policy/top-trump-officials-split-over-epstein-investigationconclusion-9449183f; Emma Colton, Dal Brass Vowed Full Transparency on Epstein Before Tuning Up Empty-Handed, Fox News (July 13, 2025, 4:56 PM), https://www.foxnews.com/ politics/doj-brass-vowed-full-transparency-epstein-before-turning-up-emptaidecl [https://perma.cc/V8SV-KSRT]; Hannah Rabinowitz et al., House Speaker Joins Growing Number of Republicans Pressing Trump Administration for More Transparency on Epstein Case, CNN (July 15, 2025, 7:05 PM), https://www.cnn.com/2025/07/15/politicskpsteinfiles-trump-bondi [https://perma.cc/7SCN-LGVZI.
+
+### II. Motion to Unseal the Maxwell Grand Jury Materials
+
+On July 18, 2025, the Deputy Attorney General ("DAG") filed a three-and-a-half-page motion to unseal the grand jury transcripts in this case. Dkt. 785 ("Motion to Unseal").7 The motion stated:
+
+On July 6, 2025, the [DOJ] and [FBI] issued a memorandum describing an exhaustive review undertaken of investigative holdings relating to Jeffrey Epstein (the "Memorandum"). The Memorandum detailed the steps taken by the [DOJ] and [FBI] to determine whether evidence existed that could predicate an investigation into uncharged third parties. As the Memorandum concluded, no such evidence was uncovered during the review.
+
+Since July 6, 2025, there has been extensive public interest in the basis for the Memorandum's conclusions. While the [DOS] and [FBI] continue to adhere to the conclusions reached in the Memorandum, transparency to the American public is of the utmost importance to this Administration. Given the public interest in the investigative work conducted by the [DOJ] and [FBI] into Epstein, the [DOJ] moves the Court to unseal the underlying grand jury transcripts in [United States v. Maxwell and] United States v. Epstein, subject to appropriate redactions of victimrelated and other personal identifying information.
+
+Id. (citation omitted), The motion noted that the Second Circuit has recognized that, in "special circumstances," release of grand jury records may be appropriate even where not authorized by Federal Rule of Criminal Procedure 6(e). Id. at 3 (citing In re Petition of Craig, 131 F.3d 99, 102 (2d Cir. 1997)) ("In re Craig").
+
+On July 22, 2025, after the case was reassigned to this judge, Dkt. 786, the Court issued an order stating that it required further information to resolve the motion, Dkt. 789. It ordered the Government, by July 29, 2025, to file a memorandum addressing the factors identified in In
+
+{sup}`7` The same day, the DAG filed a similar motion on the docket of Epstein's case. See United States v. Epstein, 19 Cr. 490 (RMB) (S.D.N.Y. July 18, 2025), Dkt. 61.
+
+{sup}`8` On July 19, 2025, the House press secretary announced that the President had directed the AG "to move forward with requesting grand juries related to the Epstein files unseal their relevant documents." House, MAGA Minute (July 19, 2025), https://www.whitehouse .gov/videos/maga-minute-july-19-2025/ [https://perma.cc/Q3BJ-V24S].
+
+re Craig; to disclose whether it had given notice of its motion to Maxwell's victims; and to file under seal the grand jury transcripts (unredacted and as redacted for proposed public release) and other grand jury materials, including exhibits. Id. at 3. The order authorized Maxwell and her victims to file, by August 5, 2025, letters addressing the Government's motion.9
+
+On July 29, 2025, the Govemment10 submitted a memorandum responding to the July 22, 2025 order. It represented that it had now given notice of its filing to all but one victim, and sought leave to file a supplemental submission responding to the victims' submissions. Dkt. 796 ("Gov't Mem."). The Government also filed, under seal, the grand jury materials the Court had requested.
+
+On July 31, 2025, the Court directed the Government to file a letter (I) stating whether, as its July 29 memorandum suggested, it was moving to unseal the grand jury exhibits along with the transcripts; and (2) identifying the portions of the grand jury transcripts and exhibits that, as proposed for public release, are not already matters of public record. Dkt. 797.
+
+On August 4, 2025, the Government submitted a letter seeking leave to advise the Court by August 8, 2025, of its position with respect to unsealing the grand jury exhibits. Dkt. 800. It also filed, under seal, a document indicating the portions of the grand jury transcripts that are not matters of public record.
+
+On August 5, 2025, Maxwell filed a letter opposing unsealing the grand jury transcripts. Dkt. 803. That day and the next, the Court docketed a total of six letters that representatives of
+
+{sup}`9` In a later order, the Court provided victims with logistical instructions for the submission (and redaction) of their letters. Dkt. 801.
+
+{sup}`10` The July 29, 2025 filing (and all ensuing Government filings) were filed by both the DAG and the United States Attorney for this District.
+
+victims and other witnesses had submitted to the Government, which the Government in turn furnished to the Court. See Dkts. 804, 806.
+
+On August 8, 2025, the Government clarified that it was moving to unseal the Maxwell grand jury exhibits, subject to appropriate redactions, in addition to the transcripts. Dkt. 808." It also submitted a sealed letter that identified the portions of those exhibits that were not already matters of public record.
+
+## III. Grand Jury Secrecy: Applicable Legal Principles
+
+## A. Federal Rule of Criminal Procedure 6(e)
+
+The policy that "proceedings before a grand jury shall generally remain secret" is "older than our Nation itself." In re Biaggi, 478 F.2d 489, 491 (2d Cir. 1973) (quoting Pittsburgh Plate Co. v. United States, 360 U.S. 395, 399 (1959)). The rule of secrecy "contribute[s] to the success of grand juries and to the protection of those who appear before them." In re Craig, 131 F.3d at 101-02. The purposes served by grand jury secrecy include:
+
+- (1) [t]o prevent the escape of those whose indictment may be contemplated;
+- (2) to insure the utmost freedom to the grand jury in its deliberations, and to prevent persons subject to indictment or their friends from importuning the grand jurors;
+- (3) to prevent subornation of perjury or tampering with the witnesses who may testify before [the] grand jury and later appear at the trial of those indicted by it;
+- (4) to encourage free and untrammeled disclosures by persons who have information with respect to the commission of crimes; [and]
+- (5) to protect [the] innocent accused who is exonerated from disclosure of the fact that he has been under investigation, and from the expense of standing trial when there was no probability of guilt.
+
+{sup}`&`quot; The Court hereinafter refers to the grand jury transcripts and exhibits together as the "grand jury materials."
+
+Id. (quoting United States v. Procter & Gamble Co., 356 U.S. 677, 681-82 n.2 (1958)) (alterations in original); see also In re Biaggi, 478 F.2d at 491-92.
+
+The rule of secrecy is today embodied in Rule 6(e), which bars disclosure of grand jury matters by persons privy to them: grand jurors, attorneys for the Government, court reporters, operators of recording devices, and interpreters. See Fed. R. Crim. P. 6(e)(2XB). Rule 6(e)(3) defines narrow exceptions. It authorizes disclosures:
+
+- to other Government personnel assisting in the enforcement of federal criminal law, id. at 6(eX3)(A)—(B);
+- to another federal grand jury, id. at 6(eX3)(C);
+- to law enforcement or national security officials, where the disclosures involve foreign-intelligence or counter-intelligence information and assist in the performance of official duties, id. at 6(e)(3)(D); and
+- to persons as authorized by a court in the district where the grand jury convened, id. at 6(eX3XE)-(F), provided the disclosure is: "preliminar[y] to or in connection with a judicial proceeding," id. at 6(eX3XEXi); "at the request of a defendant who shows that a ground may exist to dismiss the indictment because of a matter that occurred before the grand jury," id. at 6(e)(3XE)(ii); "at the request of the government, when sought by a foreign court or prosecutor for use in an official criminal investigation," id. at 6(e)(3XE)(iii); "at the request of the government if it shows that the matter may disclose a violation of State, Indian tribal, or foreign criminal law," provided that the disclosure is to an appropriate such government official for the purpose of enforcing that law, id. at 6(e)(3)(E)(iv); or "at the request of the government if it shows that the matter may disclose a violation of military criminal law under the Uniform Code of Military Justice," provided that the disclosure is to an appropriate military official for the purpose of enforcing that law, id. at 6(e)(3)(E)(v).
+
+## B. The "Special Circumstances" Doctrine
+
+The Second Circuit has recognized that in "special circumstances," the disclosure of grand jury materials may be appropriate even where it is not authorized by Rule 6(e). The Second Circuit developed this doctrine in three cases where disclosure was sought of grand jury matters claimed to be of unusual historical or public interest. See In re Biaggi, 478 F.2d at 492- 93; In re Craig, 131 F.3d at 101-02; Laws.' Comm. for 9/11 Inquiry, Inc. v. Garland, 43 F.4th
+
+276, 285-87 (2d Cir. 2022) ("Lawyers' Committee for 9/11"). The doctrine is based on the district court's supervisory authority over the grand juries it empanels. In re Craig, 131 F.3d at 102 & n.2. It today is recognized in the Second and Seventh Circuits, but not elsewhere.'2
+
+The Second Circuit has set out a "non-exhaustive list of [nine] factors that a trial court might want to consider when confronted with these highly discretionary and fact-sensitive 'special circumstances' motions." Id. at 106. These are:
+
+- (i) the identity of the party seeking disclosure;
+- (ii) whether the defendant to the grand jury proceeding or the government opposes the disclosure;
+- (iii) why disclosure is being sought in the particular case;
+- (iv) what specific information is being sought for disclosure;
+
+Before the D.C. Circuit's 2019 decision finding Rule 6(e) to supply the only bases for disclosure, district courts in that Circuit had considered—and sometimes granted—petitions to disclose grand jury materials of historical importance, citing the Second Circuit's precedents recognizing their authority to permit such disclosures. Compare In re Petition of Kutler, 800 F. Supp. 2d 42, 50 (D.D.C. 2011) (granting request to disclose President Nixon's grand jury testimony about Watergate due to its historical importance), and In re Application to Unseal Dockets Related to the Independent Counsel's 1998 Investigation of President Clinton, 308 F. Supp. 3d 314, 330-36 (D.D.C. 2018) (ordering disclosure of some grand jury materials related to the investigation of President Clinton's business dealings and his relationship with a House intern), with In re Shepard, 800 F. Supp. 2d 37, 39-40 (D.D.C. 2011) (denying as overbroad request for disclosure of all testimony and materials associated with every witness before three Watergate grand juries), and In re Nichter, 949 F. Supp. 2d 205, 212-13 (D.D.C. 2013) (denying disclosure of certain grand jury records about Watergate because at least one subject of the testimony was still alive).
+
+{sup}`12` Most Circuits to address the issue have held that the only justifications for disclosing grand jury matters are those set out in Rule 6(eX3). See, e.g., McKeever v. Barr, 920 F.3d 842, 843, 850 (D.C. Cir. 2019), cert. denied, 140 S. Ct. 597 (2020); In re Grand Jury 89-4-72, 932 F.2d 481, 488 (6th Cir. 1991); United States v. McDougal, 559 F.3d 837, 841 (8th Cir. 2009); Pitch v. United States, 953 F.3d 1226, 1241 (11th Cir. 2020) (en banc), cert. denied, 141 S. Ct. 624 (2020). The Seventh Circuit is in accord with the Second Circuit that a district court may order the release of grand jury materials upon a showing of special circumstances. See Carlson v. United States, 837 F.3d 753, 766-67 (7th Cir. 2016). The First Circuit has held that a district court may not authorize disclosure of grand jury materials based on their historical or public interest, but has left open whether a court could do so "when the fair administration of justice in a proceeding is at issue." Lepore v. United States, 27 F.4th 84, 93-94 (1st Cir. 2022).
+
+(v) how long ago the grand jury proceedings took place;
+
+(vi) the current status of the principals of the grand jury proceedings and that of their families;
+
+(vii) the extent to which the desired material—either permissibly or impermissibly—has been previously made public;
+
+(viii) whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive; and
+
+(ix) the additional need for maintaining secrecy in the particular case in question.
+
+Id.
+
+The doctrine is to be applied only in "exceptional circumstances," and it does not justify granting "garden variety" petitions for disclosure unauthorized by Rule 6(e). Id. at 103 (citation omitted). The burden is on the requestor to demonstrate that disclosure is appropriate, and "the baseline presumption [is] against disclosure." Lawyers' Committee for 9/11, 43 F.4th at 285 (alteration in original). "[T]he discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make." In re Craig, 131 F.3d at 104; see also Lawyers' Committee for 9/11, 43 F.4th at 285—86.
+
+# IV. Discussion
+
+## A. The Government's Basis for Claiming "Special Circumstances"
+
+No Rule 6(e)(3) exception authorizes the disclosure the Government proposes here: of, subject to redactions, all testimony and exhibits before the two grand juries that indicted Ghislaine Maxwell. The Government's motion to unseal does not contend otherwise. It does not argue that these materials would aid federal, state, military, tribal, or foreign law enforcement; or would be relevant to national security officials, another grand jury, or another judicial proceeding. Nor does the Government (or Maxwell) argue that the materials could reveal a
+
+ground to dismiss the indictment against her. And any such motion to dismiss on this basis today would very likely be futile, because Maxwell's conviction at trial renders all but the most serious errors in the grand jury proceedings harmless. See Midland Asphalt Corp. v. United States, 489 U.S. 794, 799-802 (1989) ("Only a defect so fundamental that it causes the grand jury no longer to be a grand jury, or the indictment no longer to be an indictment, gives rise to the constitutional right not to be tried."); United States v. Mechanik, 475 U.S. 66, 70-73 (1986).13
+
+The Government instead invokes the "special circumstances" doctrine, on the ground that there is an "abundant public interest" in obtaining additional information about Epstein and Maxwell's crimes, and the DOJ and FBI's investigation into them. Gov't Mem. at 4; see also id. at 1. It states that "[a]ttention given to the Epstein and Maxwell cases has recently intensified in the wake of the July 6, 2025 Memorandum announcing the conclusions of the Government's review into the investigation," id. at 5, and that release of the Maxwell grand July materials is essential to the goal of "transparency to the American public," which "is of the utmost importance to this Administration," Motion to Unseal at I. "Public officials, lawmakers, pundits, and ordinary citizens," it states, "remain deeply interested and concerned about the Epstein matter." Id. at 3. And the Maxwell grand jury materials, the Government represents, are "critical pieces of an important moment in our nation's history," and "(t)he time for the public to guess at what they contain should end." Id. at 3-4 (quoting In re Petition of Nat. Sec. Archive, 104 F. Supp. 3d 625, 629 (S.D.N.Y. 2015)).
+
+{sup}`13` A district court in the Southern District of Florida recently denied the Government's motion to unseal grand jury materials relating to the Government's investigation of Epstein in that district, finding that no Rule 6(e) exception applied. See Order Den. Pet. to Unseal Grand Jury Trs., In re Grand Jury 5-02 (WPB) & 7-103 (WPB), 25 Misc. 80920 (S.D. Fla. July 23, 2025), Dkt. 4. Because the Eleventh Circuit does not recognize the "special circumstances" doctrine, that argument for disclosure was not available to the Government in that district.
+
+The Government's invocation of special circumstances, however, fails at the threshold. Its entire premise—that the Maxwell grand jury materials would bring to light meaningful new information about Epstein's and Maxwell's crimes, or the Government's investigation into them—is demonstrably false.
+
+The Court, after receiving the Government's motion to unseal, ordered it to provide materials to substantiate its claim that the Maxwell grand jury materials contained undisclosed information of significant historical or public interest. Specifically, the Court ordered the Government to submit the grand jury transcripts and exhibits for in camera review, with the portions the Government proposed to redact highlighted. And it ordered the Government to file a submission identifying the portions of the transcripts and exhibits, if any, that are not today matters of public record, including based on Maxwell's month-long jury trial on the charges returned by the grand jury.
+
+The Government's submissions in response to the Court's orders were telling. They belied the Government's claim, in its motion to unseal, that the Maxwell grand jury materials contain significant, undisclosed information about Epstein's and Maxwell's crimes, or the investigation into them. Two features of these materials, which were not disclosed in the Government's motion, are noteworthy. The Court reports these here, at a level of generality that does not disclose the substance of grand jury proceedings.
+
+First, the grand juries in this case were not used for investigative purposes. They did not hear testimony from any firsthand witness to any event at issue. They did not hear testimony from any victim, eyewitness, suspect, or even a records custodian. The grand juries met instead for the quotidian purpose of returning an indictment.
+
+Each grand jury received evidence on a single day. On that day, it heard testimony from one person: a law enforcement agent who, acting as a summary witness, testified to information obtained in the Government's investigation to support the charges in the proposed indictment. The agent, responding to tightly structured questions from an Assistant United States Attorney ("AUSA"), provided highly abbreviated, hearsay accounts of the statements of select witnesses (e.g., the victims on whom counts in the proposed indictment were based).14 The agent led the jury through a PowerPoint of exhibits (e.g., photographs and business records). At the end of the testimony, the agent testified that he or she had not disclosed all that he or she knew, but had only responded to the AUSA's questions. Afterwards, each grand jury voted to return the proposed indictment."
+
+{sup}`10` Under federal law, "[i]t is entirely permissible for the ernment to use hearsay evidence in its presentation to the grand jury." United States v. 413 F.3d 201, 213 (2d Cir. 2005) (quoting United States v. Ruggiero, 934 F.2d 440, 447 (2d Cir. 1991)); see also United States v. Dukagjini, 326 F.3d 45, 54 (2d Cir. 2003) (noting the common "grand jury practice, improper at trial, of a single agent simply summarizing an investigation by others").
+
+{sup}`15` The first Maxwell grand jury met on June 29, 2020. It heard testimony from an FBI special agent. The agent's testimony lasted approximately one hour and 25 minutes, spanning 74 double-spaced transcript pages. Two exhibits were put before the grand jury: a PowerPoint containing slides referred to during the agent's testimony; and the proposed indictment of Maxwell. The same grand jury briefly met again on July 8, 2020, for the purpose of returning the "Sl" superseding indictment, which corrected two typographical errors in the indictment. Compare Dkt. 17, with Dkt. 1. The grand jury did not receive additional evidence.
+
+The second Maxwell grand jury met on March 29, 2021. It heard testimony from a New York Police Department detective. The detective's testimony lasted approximately an hour and 48 minutes, not including a brief recess, and spanned 117 double-spaced transcript pages. Nearly two-thirds of the testimony consisted of reading into the record the special agent's June 29, 2020 testimony. Six exhibits were put before the grand jury: the transcript of the June 29, 2020 grand jury testimony; the PowerPoint put before the June 29, 2020 grand jury; a new PowerPoint with further exhibits; the two earlier indictments of Maxwell; and the proposed "S2" superseding indictment.
+
+Second, the evidence put before the Maxwell grand juries is today, with only very minor exceptions, a matter of public record. The Government admitted as much in response to the Court's order: "The enclosed, annotated transcripts show that much of the information provided during the course of the grand jury testimony—with the exception of the identities of certain witnesses—was made publicly available at [Maxwell's] trial or has otherwise been publicly reported through the public statements of victims and witnesses." Dkt. 800 at 3. And because the Government proposes to redact the witnesses' identities, the exception it noted does not reflect information that the public would learn were the grand jury transcripts unsealed.
+
+The Court's review confirmed that unsealing the grand jury materials would not reveal new information of any consequence. In response to the Court's order, the Government supplied the Court with a binder highlighting any information that the Government had been unable to determine is public. Only scattered words, clauses, and occasional sentences are highlighted. These items are few and far between.16 The highlighted snippets supply, at most, tertiary details about the same conduct that was the focus of Maxwell's month-long trial. The same is so for the exhibits put before the grand juries. Save inconsequential portions of a few exhibits, these were received in evidence at Maxwell's trial. Some were reproduced in the Maxwell indictments.
+
+A member of the public familiar with the Maxwell trial record who reviewed the grand jury materials that the Government proposes to unseal would thus learn next to nothing new. The materials do not identify any person other than Epstein and Maxwell as having had sexual contact with a minor. They do not discuss or identify any client of Epstein's or Maxwell's. They do not reveal any heretofore unknown means or methods of Epstein's or Maxwell's crimes.
+
+{sup}`16` And the Government's highlighting is significantly over-inclusive: On the Court's review of the trial record, a number of items highlighted in fact were covered by testimony at Maxwell's trial.
+
+They do not reveal new venues at which their crimes occurred. They do not reveal new sources of their wealth. They do not explore the circumstances of Epstein's death. They do not reveal the path of the Government's investigation.
+
+Insofar as the motion to unseal implies that the grand jury materials are an untapped mine lode of undisclosed information about Epstein or Maxwell or confederates, they definitively are not that. A "public official" "'lawmaker," "pundit," or "ordinary citizen" "deeply interested and concerned about the Epstein matter," Motion to Unseal at 3, and who reviewed these materials expecting, based on the Government's representations, to learn new information about Epstein's and Maxwell's crimes and the investigation into them, would come away feeling disappointed and misled. There is no "there" there.
+
+This case is thus a far cry from every reported case applying the Second Circuit's "special circumstances" doctrine. In each such case, the petition to unseal, whether granted or denied, sought unique, undisclosed information. That information generally consisted of firsthand testimony from a public figure or a witness to an important event. See, e.g., In re Biaggi, 478 F.2d at 490-91 (granting petition to unseal grand jury testimony of New York City mayoral candidate Mario Biaggi); In re Craig, 131 F.3d at 101 (denying petition to unseal 1948 grand jury testimony of Harry Dexter M, an Assistant Secretary of the Treasury accused of being a Communist spy); In re Petition of Nat'l Sec. Archive, 104 F. Supp. 3d 625, 626, 629 (S.D.N.Y. 2015) ("In re National Security Archive") (granting petition to unseal 1950 grand jury records leading to the indictment of Julius and Ethel for conspiracy to commit espionage); In re Petition of Am. Hist. Ass 'n for Order Directing Release of Grand Jury Minutes, 49 F. Supp. 274, 278, 297-98 (S.D.N.Y. 1999) ("In re AHA") (granting in part and denying in part petition to unseal transcripts of 1947-1950 grand jury testimony regarding alleged espionage by State Department official Alger Hiss); see also note 12, supra (citing similar D.D.C. cases). None of these cases involved the secondhand, summary-witness testimony of law enforcement agents. None involved testimony that, by the time of the motion, had already come to light as a result of trial testimony by percipient witnesses on the indictment returned by the grand jury.
+
+The Government has not cited any case finding such materials to present a "special circumstance" that justifies the exceptional step of unsealing grand jury materials. Them is none.
+
+The one colorable argument under that doctrine for unsealing in this case, in fact, is that doing so would expose as disingenuous the Government's public explanations for moving to unseal. A member of the public, appreciating that the Maxwell grand jury materials do not contribute anything to public knowledge, might conclude that the Government's motion for their unsealing was aimed not at "transparency" but at diversion—aimed not at full disclosure but at the illusion of such. And there is precedent—In re Biaggi, the fountainhead of the Second Circuit's "special circumstances" doctrine—permitting a court to order the release of grand jury testimony to correct a movant's misleading public characterization of it.
+
+In re Biaggi arose from a motion by a mayoral candidate, Mario Biaggi, to reveal his earlier grand jury testimony, ostensibly to rebut a news report that he had invoked the Fifth Amendment. 478 F.2d at 490-91. Denying he had done so, Biaggi asked, on television and later in a motion, that the court examine his testimony and publicly confirm that he had claimed no constitutional privileges. Id. at 491. The Government moved for disclosure of Biaggi's testimony, redacted to protect others' names, and the district court granted that motion; Biaggi appealed, seeking disclosure of his testimony without redactions. Id. The Second Circuit, per Chief Judge Friendly, authorized disclosure of the testimony, emphasizing that Biaggi and the Government had waived objections to disclosure, and that others' interests could be protected by
+
+redactions. Id. at 492-93. And once Biaggi's testimony had been released, the Circuit elaborated in a supplemental opinion: In demanding that a court review his testimony, Biaggi had misleadingly implied to the public that he had answered every question before the grand jury. In fact, Biaggi had refused to answer 17 questions. Id. at 494. In these "special circumstances," the Circuit stated, "the public interest required" disclosure of Biaggi's testimony—in other words, to put the lie to Biaggi's false account. Id.
+
+This Court gave careful consideration to unsealing the Maxwell grand jury materials on a similar rationale. But with the Government having now conceded that the information it proposes to release is redundant of the public record—that this information was "made publicly available at [Maxwell's] trial or has otherwise been publicly reported"—the public interest in testing the Government's bona fides does not require the extraordinary step of unsealing grand jury records. Dkt. 800 at 3. Without any need to review the grand jury materials, the public can evaluate for itself the Government's asserted bases for making this motion.
+
+The Court therefore denies the Government's motion to unseal at the threshold. Contrary to the Government's depiction, the Maxwell grand jury testimony is not a matter of significant historical or public interest. Far from it. It consists of garden-variety summary testimony by two law enforcement agents. And the information it contains is already almost entirely a matter of longstanding public record, principally as a result of live testimony by percipient witnesses at the 2021 Maxwell trial.
+
+# B. Application of the In re Craig Factors
+
+In cases involving grand jury testimony of significant historical or public interest, In re Craig supplies a framework for evaluating whether disclosure, on balance, is warranted. It identifies non-exclusive factors that may weigh against disclosure, including the interests of the defendant and witnesses. Because the secondhand testimony at issue here is redundant of the
+
+public-record trial testimony of firsthand witnesses, and thus is not of significant historical or public interest, there is arguably no charter for even undertaking the In re Craig inquiry. After all, the "special circumstances" exception to Rule 6(e) only applies in "exceptional circumstances," not to "garden variety" grand jury testimony. In re Craig, 131 F.3d at 103 (citation omitted); see also Gov't Mem. at 3-4 ("acknowledg[ing] the extraordinary nature of [its] request").
+
+Nonetheless, for completeness, the Court evaluates the Government's motion in light of the non-exhaustive factors listed in In re Craig. The Court also addresses two other factors implicated by the motion: the perspectives of Epstein's and Maxwell's victims, as expressed in letters to the Court; and the systemic interest in grand jury secrecy.
+
+As this assessment shows, the Government has failed, by a wide margin, to carry its burden. These factors, considered together, favor denial of its motion to unseal.
+
+### 1. Identity of the Party Seeking Disclosure
+
+This factor ordinarily carries "great weight," and "the government's position should be paid considerable heed." In re Craig, 131 F.3d at 106. But the Government's position is "not dispositive." Id. "Government support cannot 'confer' disclosure, nor can government opposition preclude it." Id. And courts in this District, applying the In re Craig factors, have ruled against the Government's position. See In re National Security Archive, 104 F. Supp. 3d at 628-29 (ordering, over Government's objection, disclosure of testimony of two witnesses before grand jury that indicted Julius and Ethel for espionage); In re AHA, 49 F. Supp. 2d at 278,297-98 (ordering, over Government's objection, disclosure of testimony before grand juries that investigated and/or indicted Alger Hiss for espionage).
+
+This factor favors disclosure. But for two reasons, the Court accords this factor limited weight.
+
+First, as the Second Circuit has explained, the Government's position is mainly relevant because it reflects whether there is an ongoing need for grand jury secrecy. See In re Craig, 131 F.3d at 106 (where "the government supports a motion for disclosure, that should serve as a preliminary indication that the need for secrecy is not especially strong"). But the central infirmity of this motion to unseal does not concern an ongoing need for secrecy in this case. The infirmity is that, as the Government has conceded, the Maxwell grand jury materials do not reveal information outside the public domain.
+
+Second, any argument that the Government's motion to unseal merits substantial deference is weakened by a host of irregularities with respect to that motion. That motion was not made, nor has it been joined in, by any member of the Government's trial team—the DOJ lawyers presumably most familiar with the Maxwell case and the broader Epstein-Maxwell investigation. The motion was filed by the DAG alone, without any signatory from the U.S. Attorney's Office in this District. And it was made under circumstances suggestive of haste rather than reflective deliberation. The motion was three-and-a-half pages in length; there were no supporting materials filed, under seal or otherwise; the motion did not disclose (or reflect awareness of) the summary-witness nature of the Maxwell grand jury testimony; and the motion was made without advance notice to Epstein's and Maxwell's victims, a fact which, as reviewed below, has alarmed numerous victims. Only after the Court inquired on that point was notice to victims given. See Dkt. 789; Dkt. 796 at 9. Finally, the Government's highlighting of the grand jury transcripts did not suggest close familiarity with the Maxwell trial record, because a number of details that it identified as non-public in fact had been testified to during the trial. See note 16, supra.
+
+#### 2. Whether the Defendant to the Grand Jury Proceedings or the Government Opposes Disclosure
+
+Maxwell opposes disclosure because, among other reasons, her case remains on direct appeal. Dkt. 803 at 2 ("Because this is ongoing litigation in a criminal case involving a living defendant with existing legal remedies, the government's motion should be denied.")
+
+This factor thus weighs against unsealing. The Court, however, assigns limited weight to this factor because Maxwell, who does not have a legal right to access the grand jury materials, has not seen it. Her opposition is therefore fairly viewed as precautionary. Had Maxwell been aware that the grand jury materials are duplicative of information in the public record, her position might have been different.
+
+# 3. Why Disclosure is Being Sought in the Pat ticular Case
+
+This factor addresses the present-thy significance of the grand jury materials at issue and whether their disclosure would advance the public interest. This factor so decisively weighs against unsealing that it alone would require denying the Government's motion.
+
+Arguments to disclose grand jury testimony on account of historical or public interest are "totally appropriate" and sometimes may even be weighty. In re Craig, 131 F.3d at 106. But for the reasons reviewed above, the grand jury materials here are neither of historical nor publicinterest importance. This evidence was put before the grand juries in June 2020 and March 2021, in a case that remains on direct appeal. Cf. In re National Security Archive, 104 F. Supp. 3d at 628-29 (1950 grand jury testimony regarding Julius and Ethel ); In re AHA, 49 F. Supp. at 278,297-98 (1947-1950 grand jury testimony regarding Alger Hiss). And it is not of present-day public importance because it consists of summary testimony by law enforcement agents recounting information that today is a matter of public record, on account of the monthlong trial on the charges returned by the grand jury. Cf. In re Biaggi, 478 F.2d at 494 (grand jury testimony of mayoral candidate exposing as false his representation to the public that he had answered all questions before grand jury). And the Government's stated rationale for its motion bears no resemblance to any "grounds that justify disclosure under the existing exceptions listed in Rule 6(e)." In re Craig, 131 F.3d at 106.
+
+In arguing that this factor favors disclosure, the Government makes broad proclamations about the public's interest in learning more about the Epstein-Maxwell investigation. See Gov't Mem. at 5 ("Many questions remain unanswered, and the public's interest remains." (quoting In re AHA, 49 F. Supp. 2d at 294)). That interest is undeniable. But the Government has failed to connect it to the materials at issue, which would not answer any of the public's questions.
+
+This factor decisively weighs against unsealing.
+
+## 4. What Specific Information Is Being Sought for Disclosure
+
+"The specificity of the data sought is significant in at least two ways." In re Craig, 131 F.3d at 106.
+
+First, there are obvious differences between releasing one witness'[s] testimony, the full transcript, or merely the minutes of the proceeding. And, second, it is highly relevant whether the disclosure is general or limited to a specified number of people under special circumstances.
+
+Id. at 106-107 (citation omitted).
+
+Here, the Government does not seek tailored disclosure of discrete items within a grand jury record. Nor does it seek leave to disseminate grand jury materials to a specified audience. It seeks disclosure to the public at large of the entire proceedings before the Maxwell grand jury, subject only to redactions aimed at protecting privacy.
+
+This factor weighs against unsealing. The Government has identified no information of consequence within the grand jury record that is not already public. And, under In re Craig, the blanket quality of the motion to unseal weighs against unsealing.
+
+### 5. How Long Ago the Grand Jury Proceedings Took Place
+
+The Second Circuit has instructed:
+
+The timing of the request remains one of the most crucial elements. Time matters in several ways. First, if historical interest in a specific case has persisted over a number of years, that serves as an important indication that the public's interest in release of the information is substantial. (Hence the hypotheticals involving John Wilkes Booth and Aaron Burr.)17 Second, the passage of time erodes many of the justifications for continued secrecy. See Douglas Oil (Co. v. Petrol Stops Northwest, 441 U.S. 221, 222 (1979)] (noting that the interests in grand jury secrecy are reduced after the grand jury has ended its activities). Third, the passage of time eventually, and inevitably, brings about the death of the principal parties involved in the investigations, as well as that of their immediate families. And the continued existence and vulnerability of such parties is, of itself, a factor that a court should consider.
+
+Id. at 107 (footnote added).
+
+This factor presents countervailing considerations. On the one hand, 20-30 years have passed since Maxwell (and Epstein) committed the crimes for which they were charged. (The conduct for which Maxwell was convicted spanned 1994 to 2004.)
+
+On the other hand, the grand juries that indicted Maxwell met approximately five years ago. Maxwell's trial occurred under four years ago. Her conviction remains on direct appeal. And numerous victims of Epstein and Maxwell are still alive. These circumstances starkly contrast with most precedents in this line of cases, which involved testimony decades earlier. See, e.g., id. at 100 (1948 testimony); In re National Security Archive, 104 F. Supp. 3d at 626 (1950 testimony); In re AHA, 49 F. Supp. 2d at 277-78 (1947-1950 testimony); see also note 12, supra (citing similar D.D.C. cases). But see In re Biaggi, 478 F.2d at 492-93 (testimony less than two years earlier).
+
+{sup}`17` The Circuit, in illustrating earlier in its opinion why historical or public interest considerations could justify the release of grand jury information, stated: "To the extent that the John Wilkes Booth or Aaron Burr conspiracies, for example, led to grand jury investigations, historical interest might by now overwhelm any continued need for secrecy." Id. at 105.
+
+This factor, on balance, weighs against unsealing.
+
+#### 6. Current Status of the Principals of the Grand Jury and That of Their Families
+
+This factor is aimed primarily at protecting the reputations and interests of unindicted individuals, about whom unsealed grand jury testimony would reveal damaging information not previously disclosed. See In re Craig, 131 F.3d at 107. There is no such person or information here. Insofar as Maxwell was the subject of the grand jury testimony, this factor suggests considering here "the continued existence and vulnerability" of her and her family. Id. Maxwell is alive and so theoretically could be harmed by the disclosure of adverse testimony. But here, the grand jury materials, being cumulative of the public trial evidence, do not add anything to the formidable public record inculpating her. And no family member of hers has expressed a position on the motion to unseal. Gov't Mem. at 6. This factor is neutral.
+
+### 7. Extent to Which the Desired Material Has Previously Been Made Public
+
+"[T]he extent to which the grand jury material in a particular case has been made public is clearly relevant because even partial previous disclosure often undercuts many of the reasons for secrecy." See In re Craig, 131 F.3d at 107. Here, as explained, substantially all the information testified to by the summary witnesses in the grand juries has been revealed at Maxwell's trial. And the Government proposes to redact victim identities, consistent with the approach that it took at trial. This factor is consistent with unsealing.
+
+### 8. Whether Witnesses to the Grand Jury Proceedings Who Might be Affected by Disclosure Are Still Alive
+
+Both law enforcement agents who testified are still alive. Gov't Mem. at 7. The Government, however, proposes to redact their names. This factor is neutral.
+
+### 9. Additional Need for Maintaining Secrecy in the Case in Question
+
+The Government identifies under this factor the privacy interests of victims and third parties referenced in the grand jury materials. Id. The Government proposes to redact their names and other personally identifying information. On the Court's review, the proposed redactions would satisfactorily do so. This factor is neutral.
+
+## 10. Perspectives of Epstein's and Maxwell's Victims
+
+The Court has received, and reviewed with care and great respect, letters on behalf of numerous victims of Epstein and Maxwell. See Dkts. 804, 806. Their letters address whether the Maxwell grand jury materials should be disclosed. They also express broader concerns about recent Government actions with respect to Maxwell and the Epstein-Maxwell investigation.
+
+The letters, in the main, urge broad disclosure of the Government's investigative records regarding Epstein and Maxwell. Consistent with this view, they generally support release of the Maxwell grand jury materials, provided that, before release, any records be rigorously redacted to protect identities and privacy. See, e.g., Dkt. 804 at 6 ("We are in full agreement with the public disclosure of the grand jury transcripts, and further state that all Epstein-related information and documents in the possession and control of law enforcement, prosecutorial[,] and other government agents and entities should be fully disclosed.").
+
+This factor therefore favors unsealing. But there is an important qualification. The victims' interest in reviewing the grand jury materials appears to be premised on the understandable but mistaken belief that these materials would reveal new information. See, e.g., id. at 10 ("Unsealing the grand jury transcripts would allow additional important information to emerge ...."); id. at 9 ("[T]he instant motion for unsealing will help expose the magnitude and abhorrence of Epstein's and Maxwell's crimes."). The Government had, after all, publicly portrayed these as "critical pieces of an important moment in our nation's history." Motion to
+
+Unseal at 3. Had the Government's motion made clear that these records are redundant of the evidence at Maxwell's public trial, the victims' responses to the motion to unseal might well have been different.
+
+Various letters also express alarm or dismay at other recently reported, or anticipated, Government actions regarding Maxwell." These concerns, however, are properly directed to the political branches. The Court has not considered them in resolving the motion to unseal.
+
+### 11. The Systemic Interest in Grand Jury Secrecy
+
+A final consideration is systemic. "[T]he proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings." Douglas Oil Co., 441 U.S. at 218. For that reason, the Supreme Court has instructed lower courts "considering the effects of disclosure on grand jury proceedings" to assess "the possible effect upon the functioning of future grand juries," mindful that "[p]ersons called upon to testify will consider the likelihood that their testimony may one day be disclosed to outside parties." Id. at 222; see also Procter & Gamble Co., 356 U.S. at 682 ("The grand jury as a public institution serving the community might suffer if those testifying today knew that the secrecy of their testimony would be lifted tomorrow."); Baker v. U.S. Steel Corp., 492 F.2d 1074, 1076 n.2 (2d Cir. 1974) (similar).
+
+is These include the Government's decision, while pursuing release of the grand jury materials, to not publicly release further records from its investigation of Epstein and Maxwell, see, e.g., Dkt. 804 at 9 (noting "the much larger volume of information available in the 'more than 300 gigabytes of data and physical evidence' in the Government's possession that should be disclosed as well"); its "suggestion that no further criminal investigations are forthcoming," id. at 8; its not having given notice to victims before it filed the instant motion to unseal, id. at 8, 16, 21; its transfer of Maxwell to a lower security prison, which, a letter states, "has further eroded the victims' confidence that their safety and dignity are priorities," id. at 15; the possibility that Maxwell might receive clemency, id. at 15-16; and the DAG's decision to meet with Maxwell "as though she were a credible authority," which, one letter states, has publicly "legitimiz[ed] her," id. at 15; see also id. at 20.
+
+That admonition requires courts applying the Second Circuit's "special circumstances" exception to grand jury secrecy to invoke it only in rare, "exceptional circumstances," mindful of the precedent that unsealing would set. In re Craig, 131 F.3d at 103. The exception, after all, derives from a district court's supervisory authority over grand juries, id. at 102 & n.2, which carries with it the duty to safeguard "the traditional functioning of the institution," United States v. 504 U.S. 36, 51 (1992). Applying the exception casually or promiscuously, as the Government's motion to unseal the summary-witness grand jury testimony here invites, would risk "unravel[ing] the foundations of secrecy upon which the grand jury is premised," In re Craig, 131 F.3d at 103, and eroding confidence by persons called to testify before "future grand juries,"Doug/as Oil Co., 441 U.S. at 222, that the general rule of secrecy still holds.
+
+This factor weighs heavily against unsealing. Granting the Government's motion would bloat the "special circumstances" doctrine, which to date has warranted disclosure in only a tiny number of cases, all involving unique testimony by firsthand witnesses to events of obvious public or historical moment. And it is no answer to argue that releasing the grand jury materials, because they are redundant of the evidence at Maxwell's trial, would be innocuous. The same could be said for almost any grand jury testimony, by summary witnesses or others, given in support of charges that later proceeded to trial.
+
+## CONCLUSION
+
+For the reasons above, the Court denies the Government's motion to unseal the grand jury materials in this case. The Clerk of Court is respectfully directed to terminate the motion at docket 785.
+
+SO ORDERED.
+
+Dated: August 11, 2025 New York, New York
+
+PAUL A. ENGELMA United States District Judge 4r7

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