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Case 1:19-cr-00490-RMB Document66- Filed 07/29/25 Page 7 of 10 6. The Current Status of the Principals of the Grand Jury Proceedings and that of their Families The sixth factor considers “the current status of the principals of the grand jury proceedings and that of their families.” /n re Craig, 131 F.3d 99. The passage of time “brings about the death of the principal parties involved in the investigations, as well as that of their immediate families.” Id. at 106. The Court should consider the “continued existence and vulnerabilities of such parties.” Id. In this case, the grand jury testimony was offered specifically in connection with charges proposed against Epstein and Maxwell. Epstein is deceased, and no family member has approached the Government indicating an interest in the instant motions. One of Epstein’s family members previously filed a request for materials pursuant to the Freedom of Information Act, the Government responded to that request, and no litigation ensued. Maxwell currently is incarcerated, and no family member has approached the Government indicating an interest in the motions. 7. The Extent to Which the Desired Material—Either Permissibly or Impermissibly—Has Been Previously Made Public The Government is not aware of the relevant grand jury transcripts being impermissibly leaked to the public. Certain aspects and subject matters of the transcripts became public during Maxwell’s trial. To the extent that any of the desired material was disclosed to Maxwell as a result of the Government’s disclosure obligations, it was disclosed pursuant to a protective order. Many of the victims whose accounts relating to Epstein and Maxwell that were the subject of grand jury testimony testified at trial consistent with the accounts described by an FBI agent and the detective from the New York City Police Department (“NYPD”) in the grand jury and some have also made public those factual accounts in the course of civil litigation. The DOJ-OGR-00000752