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Case 1:19-cr-00490-RMB Document66- Filed 07/29/25 Page 8 of 10 Government is providing under seal a list of witnesses whose accounts were conveyed in the grand jury proceedings and a corresponding list noting which witnesses testified at trial. 8. Whether Witnesses to the Grand Jury Proceedings Who Might Be Affected by Disclosure Are Still Alive The eighth factor considers “whether witnesses to the grand jury proceedings who might be affected by disclosure are still alive.” Jn re Craig, 131 F.3d at 106. Here, there was one witness—an FBI agent—during the Epstein grand jury proceedings. There were two witnesses—the same FBI agent from the Epstein grand jury proceedings and a detective with the NYPD who was a Task Force Officer with the FBI’s Child Exploitation and Human Trafficking Task Force—during the Maxwell grand jury proceedings. Both witnesses are still alive; the FBI agent continues to be an agent with the FBI, and the Detective continues to be a Detective with the NYPD as well as a Task Force Officer. Consistent with applicable rules concerning the admissibility of hearsay testimony, the grand jury witnesses described statements of others, including statements of and concerming victims, many of whom are still alive. In the sealed submission accompanying this filing, the Government will note which victims are still alive. 9. Whether There Is an Additional Need for Maintaining Secrecy in the Particular Case in Question Finally, the ninth factor considers “the additional need for maintaining secrecy in the particular case in question.” Jn re Craig, 131 F.3d at 106. In addition to the typical reasons for grand jury secrecy, the grand jury transcripts contain victim-related and other personal identifying information related to third parties who neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell were charged, to which the Government is sensitive, and which is why the Government proposes redacting the transcripts before releasing them. (See Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2). DOJ-OGR-00000753