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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page11of31 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. 808.1"! It also submitted a sealed letter that identified the portions of those exhibits that were not already matters of public record. WI. 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.” Jn re Biaggi, 478 F.2d 489, 491 (2d Cir. 1973) (quoting Pittsburgh Plate Glass 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.” Jn 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. '! The Court hereinafter refers to the grand jury transcripts and exhibits together as the “grand jury materials.” 11 DOJ-OGR-00015143