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Case 1:20-cr-00330-PAE Document 804 _ Filed 08/06/25 Page 26 of 27 b. The privacy interests (iii outweigh any historical interest justifying disclosure The same legal analysis applies to the privacy interests of While the government has not provided any information about the context m which 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. 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 even if mnocuous, wili only serve to allow for at a time when the political attention on this case 1s perhaps at its most significant. C7, United States v. Amodeo (“Amodeo IT’), 71 F.3d 1044, 1051 (2d Cw. 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. Il. If the Court determines that unsealing is warranted despite the weight of precedent, redactions should be appropriately tailored to protect privacy interests In the event this Court exercises its discretionary power to unseal these grand jury materials, respectfully request that its order doing so include detailed guidance to the — on the appropriate redactions that should be applied prior to any unsealing and that be provided with copies of the materials in which they appear im 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 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.° Sek oR ok 5 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, We Cracked the Redactions in the Ghislaine Maxwell Deposition, Slate (Oct. 22, 2020, 12:31 PM), https://slate.com/news-and-politics/2020/10/ghislaine-maxwell- deposition-redactions-epstein-how-to-crack html. 4 DOJ-OGR-00015121