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Case 1:19-cr-00490-RMB Document66- Filed 07/29/25 Page 9 of 10 B. Additional Information The Court directed the Government to state whether, “before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal.” (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). Before filing the motions to unseal, relevant counsel for the Government reviewed the Epstein and Maxwell grand jury transcripts. In addition, the Government has now provided notice to all but one of the victims who are referenced in the grand jury transcripts at issue in this motion. The Government has attempted to contact the remaining victim, but such efforts have been unsuccessful. In addition, the Government is in the process of providing notice to any other individuals identified in the transcripts. C. Provision of Materials to the Court The Court directed the Government to submit: (1) indices of Epstein and Maxwell grand jury materials, including a brief summary, the number of pages, and dates; (2) a complete set of the Epstein and Maxwell grand jury transcripts; (3) a complete proposed redacted set of the Epstein and Maxwell grand jury transcripts; and (4) a description of any other Epstein and Maxwell grand jury materials, including, but not limited to, exhibits. (Epstein Dkt. 63 at 3; Maxwell Dkt. 789 at 3). As to the final category, the Government provides a description of all of the underlying materials presented to the grand jury as well as copies of, and proposed redactions to, certain materials presented to the grand jury. The Government is submitting these materials ex parte and under seal, as they relate to grand jury proceedings and include information related to victims, including but not limited to victim-identifying information of individuals who neither testified at trial or who were the subject of testimony at trial. The Government underscores that it takes very seriously its obligation to DOJ-OGR-00000754