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868 KB
Extraction Summary
3
People
3
Organizations
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Locations
4
Events
3
Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
868 KB
Summary
This legal document is a filing on behalf of victims in the Epstein/Maxwell case, respectfully requesting the Court to implement specific protective measures before unsealing grand jury materials. The requests include requiring the government to confer with victims' counsel, judicial in-camera review of the materials, and pre-release review by victims' counsel to propose redactions. The filing argues these safeguards are essential to protect the survivors' safety, privacy, and dignity from further trauma, especially given recent events concerning Ms. Maxwell.
People (3)
| Name | Role | Context |
|---|---|---|
| Paul A. Engelmayer | Honorable |
Addressed at the top of the document, likely the presiding judge.
|
| Epstein | Perpetrator |
Mentioned in the context of 'Epstein/Maxwell victims' and 'the years of Epstein’s abuse'.
|
| Ms. Maxwell | Perpetrator/Defendant |
Mentioned in the context of 'Epstein/Maxwell victims', her 'sex-trafficking conviction and perjury charges', her 'tra...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
The judicial body being petitioned to grant the requested relief.
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| Government | Government agency |
The party that is being requested to confer with victims' counsel before the release of grand jury materials.
|
| Douglas Oil | Company |
Referenced as a legal precedent ('consistent with Douglas Oil') concerning the scope of disclosure of grand jury mate...
|
Timeline (4 events)
Ms. Maxwell's sex-trafficking conviction and perjury charges.
A government request to unseal grand jury materials was filed without conferral.
Relationships (3)
The document refers to 'Epstein/Maxwell victims', linking them together in relation to the crimes committed.
The document explicitly mentions 'the years of Epstein’s abuse' and the 'profound violations of their rights and dignity' endured by the survivors.
The document refers to 'Epstein/Maxwell victims' and Ms. Maxwell's 'sex-trafficking conviction'.
Full Extracted Text
Complete text extracted from the document (2,866 characters)
Case 1:20-cr-00330-PAE Document 804 Filed 08/06/25 Page 17 of 27
Honorable Paul A. Engelmayer
Case No.: 1:20-cr-00330 (PAE)
Page 4
Case No.: 1:20-cr-00330 (PAE)
Page 4
this approach. See, e.g., 18 U.S.C. § 3509(d)(2) (authorizing protective orders to shield child-victims’
identities and “other information concerning a child”); Fed. R. Crim. P. 49.1 (privacy redactions).
Many Epstein/Maxwell victims were minors at the time of the abuse; even for those now adults, §
3771(a)(8), and the Court’s protective authority warrant safeguards that functionally align with §
3509(d) principles.
identities and “other information concerning a child”); Fed. R. Crim. P. 49.1 (privacy redactions).
Many Epstein/Maxwell victims were minors at the time of the abuse; even for those now adults, §
3771(a)(8), and the Court’s protective authority warrant safeguards that functionally align with §
3509(d) principles.
III. Requested Relief
In light of the foregoing, the victims respectfully request that the Court:
1) Require Conferral and Notice (CVRA §§ 3771(a)(5), (c)(1)): Direct the Government to
confer with victims’ counsel and provide reasonable notice and an opportunity to be heard
before any ruling on unsealing or public release of grand jury materials.
confer with victims’ counsel and provide reasonable notice and an opportunity to be heard
before any ruling on unsealing or public release of grand jury materials.
2) Judicial In Camera Review: Conduct a comprehensive in camera review of the grand jury
materials to determine whether the proponent has shown a Rule 6(e)-compliant basis for any
disclosure and, if so, the narrowest scope of disclosure consistent with Douglas Oil.
materials to determine whether the proponent has shown a Rule 6(e)-compliant basis for any
disclosure and, if so, the narrowest scope of disclosure consistent with Douglas Oil.
3) Victims’ Counsel Pre-Release Review (Under Protective Order): Permit designated victims’
counsel to review the government’s proposed redactions and any index of materials under a
strict protective order, to allow victims’ counsel to identify and present: (a) direct identifiers,
(b) combinations of data points that could reasonably lead to re-identification or harassment
of victims, and (c) to propose all additional redactions necessary.
counsel to review the government’s proposed redactions and any index of materials under a
strict protective order, to allow victims’ counsel to identify and present: (a) direct identifiers,
(b) combinations of data points that could reasonably lead to re-identification or harassment
of victims, and (c) to propose all additional redactions necessary.
4) Dispute Resolution before Unsealing or Release: If the government does not agree with
additional proposed redactions from victims’ counsel, provide victims’ counsel the
opportunity to be heard on any dispute before ruling on unsealing or public release.
additional proposed redactions from victims’ counsel, provide victims’ counsel the
opportunity to be heard on any dispute before ruling on unsealing or public release.
5) Defer or Deny Without Prejudice if Safeguards Cannot Be Assured: If adequate safeguards
cannot be implemented consistent with Rule 6(e), Pitch, and the CVRA, deny disclosure
without prejudice.
cannot be implemented consistent with Rule 6(e), Pitch, and the CVRA, deny disclosure
without prejudice.
IV. Conclusion
The survivors support transparency when it can be achieved without sacrificing their safety, privacy,
or dignity. But transparency cannot come at the expense of the very people whom the justice system
is sworn to protect–particularly amid contemporaneous events that magnify risk and trauma: the
public platforming of Ms. Maxwell as a purportedly credible commentator despite her sex-trafficking
conviction and perjury charges, her transfer to lower-security custody, a government request to unseal
filed without conferral, and the looming specter of clemency.
or dignity. But transparency cannot come at the expense of the very people whom the justice system
is sworn to protect–particularly amid contemporaneous events that magnify risk and trauma: the
public platforming of Ms. Maxwell as a purportedly credible commentator despite her sex-trafficking
conviction and perjury charges, her transfer to lower-security custody, a government request to unseal
filed without conferral, and the looming specter of clemency.
These survivors have already endured profound violations of their rights and dignity, both during
the years of Epstein’s abuse and in the years following. To now compound their trauma by sidelining
the years of Epstein’s abuse and in the years following. To now compound their trauma by sidelining
DOJ-OGR-00015112
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