DOJ-OGR-00000767.jpg

Case 1:19-cr-00490-RMB Document 72 Filed 08/05/25 Page 2 of 5

BSF

It is obviously impossible for two people to conduct a decades-long sex-trafficking enterprise involving thousands of victims without other individuals who participated in and facilitated these unspeakable atrocities.

The recent controversy surrounding the Government’s decision to withhold information concerning Epstein’s and Maxwell’s crimes has largely ignored the victims’ perspective. Ms. Farmer is thankful for the Court’s invitations to state the victims’ positions, and supports the unsealing of the grand jury transcripts, as well as the accompanying grand jury exhibits, with redactions only as necessary to protect victims’ names, likenesses, and identifying information. Transparency is critical to justice, and the public has a legitimate interest in understanding the full scope of Epstein’s and Maxwell’s crimes, particularly where those actions caused lasting harm to others. While it was not the victims’ decision to seek disclosure of the grand jury transcripts alone (as opposed to the much larger volume of information available in the “more than 300 gigabytes of data and physical evidence” in the Government’s possession that should be disclosed as well), the instant motion for unsealing will help expose the magnitude and abhorrence of Epstein’s and Maxwell’s crimes.

In this case that involved a decades-long, systematic criminal scheme that shocked the conscience of the public, caused lasting harm to survivors, and raised credible concerns about the failures of institutional accountability, there is an especially compelling interest in transparency. Unsealing the grand jury transcripts will illuminate the scope of Epstein’s and Maxwell’s abuse, provide additional insight into those who enabled his abuse, and bring light to how these crimes were investigated and prosecuted. While grand jury secrecy serves important purposes, it is not absolute and under these circumstances the balance tilts in favor of disclosure.

1. Given the Magnitude and Abhorrence of Epstein’s and Maxwell’s Crimes, the Unsealing of the Grand Jury Transcripts Is Appropriate.

The Second Circuit has recognized that there are special circumstances when the release of grand jury records is appropriate based on the courts’ supervisory authority over the grand juries they empanel and that the trial court has “wide discretion … in evaluating whether disclosure is appropriate.” In re Petition of Craig, 131 F.3d 99, 102, 104 (2d Cir. 1997). In Craig, the Second Circuit outlined a non-exclusive list of factors that a trial court may consider when deciding whether “special circumstances warrant the release of grand jury transcripts. Id. at 106. We join the Government’s arguments for unsealing under the Craig factors, Epstein Dkt No. 66, at 3–7. Two factors warrant additional discussion in light of the victims’ position in favor of unsealing.

or commutation of her sentence. The victims of her crimes unequivocally object to any potential leniency that the Government may be considering offering Maxwell, a convicted sex trafficker.

2

DOJ-OGR-00000767