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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page 16 of 31 The Government’s invocation of special circumstances, however, fails at the threshold. Its entire premise—that the Maxwell grand jury materials would bring to light meaningful new information about Epstein’s and Maxwell’s crimes, or the Government’s investigation into them—is demonstrably false. The Court, after receiving the Government’s motion to unseal, ordered it to provide materials to substantiate its claim that the Maxwell grand jury materials contained undisclosed information of significant historical or public interest. Specifically, the Court ordered the Government to submit the grand jury transcripts and exhibits for in camera review, with the portions the Government proposed to redact highlighted. And it ordered the Government to file a submission identifying the portions of the transcripts and exhibits, if any, that are not today matters of public record, including based on Maxwell’s month-long jury trial on the charges returned by the grand jury. The Government’s submissions in response to the Court’s orders were telling. They belied the Government’s claim, in its motion to unseal, that the Maxwell grand jury materials contain significant, undisclosed information about Epstein’s and Maxwell’s crimes, or the investigation into them. Two features of these materials, which were not disclosed in the Government’s motion, are noteworthy. The Court reports these here, at a level of generality that does not disclose the substance of grand jury proceedings. First, the grand juries in this case were not used for investigative purposes. They did not hear testimony from any firsthand witness to any event at issue. They did not hear testimony from any victim, eyewitness, suspect, or even a records custodian. The grand juries met instead for the quotidian purpose of returning an indictment. 16 DOJ-OGR-00015148