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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page 25 of 31 testimony of mayoral candidate exposing as false his representation to the public that he had answered all questions before grand jury). And the Government’s stated rationale for its motion bears no resemblance to any “grounds that justify disclosure under the existing exceptions listed in Rule 6(e).” Jn re Craig, 131 F.3d at 106. In arguing that this factor favors disclosure, the Government makes broad proclamations about the public’s interest in learning more about the Epstein-Maxwell investigation. See Gov’t Mem. at 5 (“Many questions remain unanswered, and the public’s interest remains.” (quoting Jn re AHA, 49 F. Supp. 2d at 294)). That interest is undeniable. But the Government has failed to connect it to the materials at issue, which would not answer any of the public’s questions. This factor decisively weighs against unsealing. 4. What Specific Information Is Being Sought for Disclosure “The specificity of the data sought is significant in at least two ways.” In re Craig, 131 F.3d at 106. First, there are obvious differences between releasing one witness’[s] testimony, the full transcript, or merely the minutes of the proceeding. And, second, it is highly relevant whether the disclosure is general or limited to a specified number of people under special circumstances. Id. at 106—107 (citation omitted). Here, the Government does not seek tailored disclosure of discrete items within a grand jury record. Nor does it seek leave to disseminate grand jury materials to a specified audience. It seeks disclosure to the public at large of the entire proceedings before the Maxwell grand jury, subject only to redactions aimed at protecting privacy. This factor weighs against unsealing. The Government has identified no information of consequence within the grand jury record that is not already public. And, under Jn re Craig, the blanket quality of the motion to unseal weighs against unsealing. 25 DOJ-OGR-00015157