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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page 21 of 31 redactions. /d. at 492-93. And once Biaggi’s testimony had been released, the Circuit elaborated in a supplemental opinion: In demanding that a court review his testimony, Biaggi had misleadingly implied to the public that he had answered every question before the grand jury. In fact, Biaggi had refused to answer 17 questions. /d. at 494. In these “special circumstances,” the Circuit stated, “the public interest required” disclosure of Biaggi’s testimony—in other words, to put the lie to Biaggi’s false account. /d. This Court gave careful consideration to unsealing the Maxwell grand jury materials on a similar rationale. But with the Government having now conceded that the information it proposes to release is redundant of the public record—that this information was “made publicly available at [Maxwell’s] trial or has otherwise been publicly reported”—the public interest in testing the Government’s bona fides does not require the extraordinary step of unsealing grand jury records. Dkt. 800 at 3. Without any need to review the grand jury materials, the public can evaluate for itself the Government’s asserted bases for making this motion. The Court therefore denies the Government’s motion to unseal at the threshold. Contrary to the Government’s depiction, the Maxwell grand jury testimony is not a matter of significant historical or public interest. Far from it. It consists of garden-variety summary testimony by two law enforcement agents. And the information it contains is already almost entirely a matter of longstanding public record, principally as a result of live testimony by percipient witnesses at the 2021 Maxwell trial. B. Application of the In re Craig Factors In cases involving grand jury testimony of significant historical or public interest, /n re Craig supplies a framework for evaluating whether disclosure, on balance, is warranted. It identifies non-exclusive factors that may weigh against disclosure, including the interests of the defendant and witnesses. Because the secondhand testimony at issue here is redundant of the 21 DOJ-OGR-00015153