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Case 1:20-cr-00330-PAE Document 803 Filed 08/05/25 Page 5 of 9

when Maxwell’s legal and reputational interests are at stake. These factors weigh heavily in favor of preserving the secrecy of the grand jury materials.

Although the government’s memorandum sets forth that certain “aspects and subject matters of the transcript became public during Maxwell’s trial,” Maxwell has never had an opportunity to review the entirety of the grand jury materials in her case. Dkt 796 at 7. The government provided a list to the Court, under seal, of witnesses whose accounts were conveyed in the grand jury and a corresponding list noting which witnesses testified at trial. That list has not been disclosed to us. The government’s memorandum, however, acknowledges that the law enforcement witnesses who testified before the grand jury are alive and remain active in the FBI and NYPD respectively. The government’s memorandum also disclosed that “many” of the complaining witnesses, who formed the subject matter of the grand jury witnesses’ testimony, are also alive. Dkt. 796 at 8. This factor likewise counsels against disclosure of the grand jury transcripts given the need to protect both active law enforcement personnel and alleged victims.

III. THERE IS NO PRECEDENT SUPPORTING RELEASE OF GRAND JURY TRANSCRIPTS IN A PENDING CASE LIKE THIS ONE

None of the cases cited by the government justify disclosure here. In re Petition of National Security Archive involved a decades-old grand jury proceeding against Julius and Ethel Rosenberg relating to charges of conspiracy to commit espionage by providing information about the atomic bomb to Soviet agents. 104 F. Supp. 3d 625, 626 (S.D.N.Y. 2015). In 1951, the Rosenbergs were tried, convicted, and sentenced to death. They were executed in 1953. Id. In 2015, upon a motion by a non-profit

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