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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page9of31 I. 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’’).’ 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 [DOJ] 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 victim- related 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). /d. at 3 (citing Jn 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 Jn 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. 8 On July 19, 2025, the White 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.” White House, MAGA Minute (July 19, 2025), https://www.whitehouse .gov/videos/maga-minute-july-19-2025/ [https://perma.cc/Q3BJ-V24S]. 9 DOJ-OGR-00015141