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Case 1:20-cr-00330-PAE Document 809 _ Filed 08/11/25 Page 29 of 31 Unseal at 3. Had the Government’s motion made clear that these records are redundant of the evidence at Maxwell’s public trial, the victims’ responses to the motion to unseal might well have been different. Various letters also express alarm or dismay at other recently reported, or anticipated, Government actions regarding Maxwell.'* These concerns, however, are properly directed to the political branches. The Court has not considered them in resolving the motion to unseal. 11. The Systemic Interest in Grand Jury Secrecy A final consideration is systemic. “[T]he proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings.” Douglas Oil Co., 441 U.S. at 218. For that reason, the Supreme Court has instructed lower courts “considering the effects of disclosure on grand jury proceedings” to assess “the possible effect upon the functioning of future grand juries,” mindful that “[p]ersons called upon to testify will consider the likelihood that their testimony may one day be disclosed to outside parties.” /d. at 222; see also Procter & Gamble Co., 356 U.S. at 682 (“The grand jury as a public institution serving the community might suffer if those testifying today knew that the secrecy of their testimony would be lifted tomorrow.”); Baker v. U.S. Steel Corp., 492 F.2d 1074, 1076 n.2 (2d Cir. 1974) (similar). '8 These include the Government’s decision, while pursuing release of the grand jury materials, to not publicly release further records from its investigation of Epstein and Maxwell, see, e.g., Dkt. 804 at 9 (noting “the much larger volume of information available in the ‘more than 300 gigabytes of data and physical evidence’ in the Government’s possession that should be disclosed as well”); its “suggestion that no further criminal investigations are forthcoming,” id. at 8; its not having given notice to victims before it filed the instant motion to unseal, id. at 8, 16, 21; its transfer of Maxwell to a lower security prison, which, a letter states, “has further eroded the victims’ confidence that their safety and dignity are priorities,” id. at 15; the possibility that Maxwell might receive clemency, id. at 15—16; and the DAG’s decision to meet with Maxwell “as though she were a credible authority,” which, one letter states, has publicly “legitimiz[ed] her,” id. at 15; see also id. at 20. 29 DOJ-OGR-00015161