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Case 1:20-cr-00330-PAE Document 804 _ Filed 08/06/25 Page 17 of 27 Honorable Paul A. Engelmayer Case No.: 1:20-cr-00330 (PAE) Page 4 this approach. See, e.g., 18 U.S.C. § 8509(d)(2) (authorizing protective orders to shield child-victims’ identities and “other information concerning a child”); Fed. R. Crim. P. 49.1 (privacy redactions). Many Epsteim/Maxwell victims were minors at the time of the abuse; even for those now adults, § 377 1(a)(8,) and the Court’s protective authority warrant safeguards that functionally align with § 3509(d) principles. III. | Requested Relief In light of the foregomg, the victims respectfully request that the Court: 1) Require Conferral and Notice (CVRA §§ 3771(a)(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 government’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 poimts 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 the 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), Préch, 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 the justice system is sworn to protect—particularly amid contemporancous events that magnify risk aud trauma: the public platforming 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 sidelming DOJ-OGR-00015112