DOJ-OGR-00015063.jpg
764 KB
Extraction Summary
4
People
5
Organizations
2
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal memorandum / court filing
File Size:
764 KB
Summary
This document is a legal memorandum filed by the Government (Department of Justice) on July 29, 2025 (per header), responding to court orders regarding motions to unseal grand jury transcripts in the Epstein and Maxwell cases. The Government argues for balancing transparency with the obligation to protect victims and cites Second Circuit case law allowing the release of grand jury records under 'special circumstances.' A footnote notes a Circuit split and mentions that Judge Robin L. Rosenberg previously denied a similar request in the Southern District of Florida regarding 2005 and 2007 Epstein records.
People (4)
| Name | Role | Context |
|---|---|---|
| Epstein | Defendant/Subject |
Referenced in docket numbers (Epstein Dkt.) and regarding 2005/2007 grand jury transcripts.
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| Maxwell | Defendant/Subject |
Referenced in docket numbers (Maxwell Dkt.) regarding pending motions.
|
| Friendly, C.J. | Judge |
Cited in case law (In re Biaggi) regarding special circumstances for releasing records.
|
| Robin L. Rosenberg | Judge |
Honorable Judge in the Southern District of Florida who denied a similar motion to unseal Epstein transcripts.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| The Government |
The filing party (Department of Justice).
|
|
| The Court |
The judicial body receiving the memorandum (Southern District of New York).
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| Second Circuit |
Court of Appeals whose precedents are cited.
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| Eleventh Circuit |
Court of Appeals mentioned in the footnote regarding a circuit split.
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| First Circuit |
Court of Appeals mentioned in the footnote.
|
Timeline (2 events)
07/29/25
Filing of Government memorandum regarding unsealing of grand jury transcripts.
Court (SDNY)
Locations (2)
| Location | Context |
|---|---|
|
Location where previous relief was sought regarding Epstein transcripts.
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Referring to the court where this document is filed (implied Southern District of New York based on case number).
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Relationships (2)
Judge Rosenberg denied the Government's motion to unseal transcripts in SD Florida.
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
DOJ-OGR-00015063.jpg
Quote #1
"there are certain ‘special circumstances’ in which release of grand jury records is appropriate even outside the boundaries of the rule."Source
DOJ-OGR-00015063.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,294 characters)
Case 1:20-cr-00330-PAE Document 796 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-00015063
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