DOJ-OGR-00000770.jpg

Case 1:19-cr-00490-RMB Document 72 Filed 08/05/25 Page5of5 BSF 2024). Thus, Ms. Farmer’s and other victims’ privacy interests as victims of Epstein and Maxwell weigh heavily in favor of the redactions of the victims’ names and identifying information. B. Redactions of Names and Information Relating to Epstein and Maxwell’s Co- Conspirators Are Improper. The Government’s original motion refers to a July 6, 2025 Memorandum that concluded that no evidence could predicate an investigation into uncharged third parties associated with Epstein’s and Maxwell’s criminal scheme. Epstein Dkt. No. 61 at 1-2. The Government purports to seek the unsealing of the grand jury transcripts to provide transparency for the public into the conclusions reached by the Memorandum. /d. To be clear, we do not agree that there is insufficient evidence to support investigations into third parties who enabled Epstein’s and Maxwell’s crimes and participated in them. Numerous individuals have yet to be investigated and several civil cases have been filed addressing other individuals’ central involvement with Epstein’s and Maxwell’s sex trafficking. As the Court acknowledged, there are “over one thousand victims” of Epstein’s and Maxwell’s crimes. Epstein Dkt. 63 at 4. Less than one-fifth of these victims have been compensated for the crimes committed against them, either through the now-closed Epstein Victims Compensation Fund or otherwise. To rectify this, there have been numerous civil cases filed that address third parties’ central involvement with Epstein and Maxwell’s sex-trafficking crimes. See Doe I v. JP Morgan Chase Bank, N.A., Case No. 22-cv-10019 (S.D.N.Y.), Doe J v. Deutsche Bank Aktiengesellschaft, Case No. 22-cv-10018 (S.D.N.Y.); Doe 3 v. Indyke, Case No. 24-cv-01204 (S.D.N.Y.). To the extent any of Epstein’s and Maxwell’s enablers and co- conspirators who have thus far evaded accountability are implicated by the grand jury transcripts, their identities should not be shielded from the public. Though “[t]he privacy interests of innocent third parties” like the victims should be redacted, see Gardner v. Newsday, Inc., 895 F.2d 74, 79 (2d Cir. 1990), there should be no similar protection for those third parties accused of wrongdoing. 3s 2K 3 Ms. Farmer strongly supports the release of Epstein’s and Maxwell’s grand jury transcripts, subject to appropriate redactions of the victims’ names and identifying information. Unsealing the grand jury transcripts serves the interests of transparency, accountability, and restorative justice. Respectfully submitted, /s/ Sigrid §. McCawley Sigrid S. McCawley Counsel for Annie Farmer DOJ-OGR-00000770