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Case 1:20-cr-00330-PAE Document 804 _ Filed 08/06/25 Page 27 of 27 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—imeet its high burden to show why unsealing grand jury materials that mention innocent third parties such a who were not the subject of any charges in relation to this case, is merited. And it certainly cannot meet such a burden with respect to any materials that Accordingly, the Court should order that the transcripts remain under seal, or, if the 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. Respectfully submitted, Neil S. Binder DOJ-OGR-00015122