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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page18 of 31 Second, the evidence put before the Maxwell grand juries is today, with only very minor exceptions, a matter of public record. The Government admitted as much in response to the Court’s order: “The enclosed, annotated transcripts show that much of the information provided during the course of the grand jury testimony—with the exception of the identities of certain witnesses—was made publicly available at [Maxwell’s] trial or has otherwise been publicly reported through the public statements of victims and witnesses.” Dkt. 800 at 3. And because the Government proposes to redact the witnesses’ identities, the exception it noted does not reflect information that the public would learn were the grand jury transcripts unsealed. The Court’s review confirmed that unsealing the grand jury materials would not reveal new information of any consequence. In response to the Court’s order, the Government supplied the Court with a binder highlighting any information that the Government had been unable to determine is public. Only scattered words, clauses, and occasional sentences are highlighted. These items are few and far between.'® The highlighted snippets supply, at most, tertiary details about the same conduct that was the focus of Maxwell’s month-long trial. The same is so for the exhibits put before the grand juries. Save inconsequential portions of a few exhibits, these were received in evidence at Maxwell’s trial. Some were reproduced in the Maxwell indictments. A member of the public familiar with the Maxwell trial record who reviewed the grand jury materials that the Government proposes to unseal would thus learn next to nothing new. The materials do not identify any person other than Epstein and Maxwell as having had sexual contact with a minor. They do not discuss or identify any client of Epstein’s or Maxwell’s. They do not reveal any heretofore unknown means or methods of Epstein’s or Maxwell’s crimes. ‘© And the Government’s highlighting is significantly over-inclusive: On the Court’s review of the trial record, a number of items highlighted in fact were covered by testimony at Maxwell’s trial. 18 DOJ-OGR-00015150