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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page19 of 31 They do not reveal new venues at which their crimes occurred. They do not reveal new sources of their wealth. They do not explore the circumstances of Epstein’s death. They do not reveal the path of the Government’s investigation. Insofar as the motion to unseal implies that the grand jury materials are an untapped mine lode of undisclosed information about Epstein or Maxwell or confederates, they definitively are 99 66. not that. A “public official,” “lawmaker,” “pundit,” or “ordinary citizen” “deeply interested and concerned about the Epstein matter,” Motion to Unseal at 3, and who reviewed these materials expecting, based on the Government’s representations, to learn new information about Epstein’s and Maxwell’s crimes and the investigation into them, would come away feeling disappointed and misled. There is no “there” there. This case is thus a far cry from every reported case applying the Second Circuit’s “special circumstances” doctrine. In each such case, the petition to unseal, whether granted or denied, sought unique, undisclosed information. That information generally consisted of firsthand testimony from a public figure or a witness to an important event. See, e.g., In re Biaggi, 478 F.2d at 490-91 (granting petition to unseal grand jury testimony of New York City mayoral candidate Mario Biaggi); /n re Craig, 131 F.3d at 101 (denying petition to unseal 1948 grand jury testimony of Harry Dexter White, an Assistant Secretary of the Treasury accused of being a Communist spy); /n re Petition of Nat’l Sec. Archive, 104 F. Supp. 3d 625, 626, 629 (S.D.N.Y. 2015) (“dn re National Security Archive”) (granting petition to unseal 1950 grand jury records leading to the indictment of Julius and Ethel Rosenberg for conspiracy to commit espionage); In re Petition of Am. Hist. Ass’n for Order Directing Release of Grand Jury Minutes, 49 F. Supp. 274, 278, 297-98 (S.D.N.Y. 1999) (“dn re AHA’) (granting in part and denying in part petition to unseal transcripts of 1947—1950 grand jury testimony regarding alleged espionage 19 DOJ-OGR-00015151