796.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 10
- Text status
- Searchable text available
- OCR confidence
- 0.9330177692194016
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 796 Filed 07/29/25 Page1of10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA = Vv. = 19 Cr. 490 (RMB) JEFFREY EPSTEIN, Defendant. UNITED STATES OF AMERICA | Vv. = 20 Cr. 330 (PAE) GHISLAINE MAXWELL, Defendant. GOVERNMENT’S MEMORANDUM IN RESPONSE TO THE COURT’S ORDERS OF JULY 22, 2025 PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278 DOJ-OGR- 00015062
Case 1:20-cr-00330-PAE Document 796 Filed 07/29/25 Page 2of10 I. Preliminary Statement The Government respectfully submits this memorandum in response to the Court’s Orders conceming the two pending motions to unseal grand jury transcripts (Epstein Dkt. 61; Maxwell Dkt. 785) in cases prosecuted in this District. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). This memorandum, as directed by the Court, addresses the specific facts and factors highlighted in the Court’s Orders relevant to the particular grand jury materials at issue here. (Epstein Dkt. 63 at 1-3; Maxwell Dkt. 789 at 1-3). In order to ensure that “[t]ransparency in this process ... not be at the expense of [the Government’s] obligation under the law to protect victims” (Epstein Dkt. 61 at 2; Maxwell Dkt. 785 at 2), the Government also respectfully requests leave to file a supplemental submission once the Government and the Court have received any filings from the victims or others referenced in the transcripts. Il. The Court’s Orders As the Court recognized (Epstein Dkt. 63 at 1-2; Maxwell Dkt. 789 at 1—2), the Second Circuit has held that “there are certain ‘special circumstances’ in which release of grand jury records is appropriate even outside the boundaries of the rule.” /n re Craig, 131 F.3d 99, 102 (2d Cir. 1997); see also In re Biaggi, 478 F.2d 489, 494 (2d Cir. 19…
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