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763 KB
Extraction Summary
6
People
6
Organizations
1
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
763 KB
Summary
This legal memorandum is submitted by the Government in response to court orders regarding motions to unseal grand jury transcripts in the cases of Epstein and Maxwell. The Government outlines the legal framework for such a release, citing a 'Circuit split' on the issue and precedent from the Second Circuit, while emphasizing its duty to protect victims. It also references a prior, unsuccessful attempt to unseal similar transcripts related to Epstein in the Southern District of Florida.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned in relation to court dockets (Dkt. 61, Dkt. 63) and a case in the Southern District of Florida involving gr...
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| Maxwell |
Mentioned in relation to court dockets (Dkt. 785, Dkt. 789).
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| Craig |
Party in the case citation 'In re Craig, 131 F.3d 99, 102 (2d Cir. 1997)'.
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| Biaggi |
Party in the case citation 'In re Biaggi, 478 F.2d 489, 494 (2d Cir. 1973)'.
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| Friendly, C.J. | Chief Judge |
Cited as the author of a supplemental opinion in the 'In re Biaggi' case.
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| Robin L. Rosenberg | Honorable (Judge) |
Mentioned as the judge in the Southern District of Florida who denied the Government's motion to unseal grand jury tr...
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
The party submitting the memorandum to the Court, likely referring to the U.S. Department of Justice.
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| The Court | government agency |
The judicial body to which the memorandum is addressed and which issued the orders being responded to.
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| Second Circuit | government agency |
A U.S. Court of Appeals whose legal holdings on the release of grand jury records are cited.
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| Eleventh Circuit | government agency |
A U.S. Court of Appeals mentioned in a footnote regarding a 'Circuit split' and whose rule bound Judge Rosenberg.
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| First Circuit | government agency |
A U.S. Court of Appeals mentioned in a case citation in the footnote.
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| Southern District of Florida | government agency |
The U.S. District Court where the Government previously sought to unseal grand jury transcripts related to Epstein.
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Timeline (2 events)
2025-07-29
The Government filed a memorandum in response to the Court's orders regarding motions to unseal grand jury transcripts.
The Government sought to unseal grand jury transcripts from 2005 and 2007 relating to Epstein in the Southern District of Florida, but the motion was denied by Judge Robin L. Rosenberg.
Southern District of Florida
Locations (1)
| Location | Context |
|---|---|
|
Location of a prior case where the Government sought to unseal grand jury transcripts relating to Epstein.
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Relationships (2)
Their cases are linked, with motions and dockets being discussed together in this single memorandum (Epstein Dkt. 61; Maxwell Dkt. 785).
The Government previously appeared before Judge Rosenberg in the Southern District of Florida, where she denied their motion to unseal grand jury transcripts related to Epstein.
Key Quotes (2)
"[t]ransparency in this process … not be at the expense of [the Government’s] obligation under the law to protect victims"Source
— The Court (cited from Epstein Dkt. 61 and Maxwell Dkt. 785)
(Quoted from the Court's orders to emphasize the need to balance transparency with victim protection.)
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Quote #1
"there are certain ‘special circumstances’ in which release of grand jury records is appropriate even outside the boundaries of the rule."Source
— Second Circuit
(A holding from the Second Circuit cited to establish the legal standard for unsealing grand jury transcripts.)
DOJ-OGR-00000747.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,293 characters)
Case 1:19-cr-00490-RMB Document 66 Filed 07/29/25 Page 2 of 10
I. Preliminary Statement
The Government respectfully submits this memorandum in response to the Court’s Orders concerning 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.
II. 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.” In re Craig, 131 F.3d 99, 102 (2d Cir. 1997); see also In re Biaggi, 478 F.2d 489, 494 (2d Cir. 1973) (supplemental opinion) (Friendly, C.J.) (recognizing that there are certain “special circumstances” in which release of grand jury records is appropriate even outside of the boundaries of Rule 6(e)).¹ The Second Circuit enumerated a list of non-exhaustive factors for trial courts to consider when deciding such motions:
¹ There is currently a Circuit split. See Pitch v. United States, 953 F.3d 1226, 1233 & n.6 (11th Cir. 2020) (en banc) (describing the Circuit split); In re Petition for Order Directing Release of Records, 27 F.4th 84, 90–91 (1st Cir. 2022) (same). In light of this split, when the Government sought similar relief seeking to unseal grand jury transcripts in the Southern District of Florida from 2005 and 2007 relating to Epstein, the Honorable Robin L. Rosenberg—who is bound by the Eleventh Circuit’s rule barring extra-Rule disclosures set forth in Pitch—denied that motion. In re
DOJ-OGR-00000747
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