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687 KB
Extraction Summary
4
People
4
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court brief
File Size:
687 KB
Summary
This document is a legal filing (Page 23 of 31) arguing against a Government motion to unseal grand jury materials in the Ghislaine Maxwell case. The text highlights procedural irregularities, noting that the motion was filed solely by the Deputy Attorney General (DAG) without the support of the local U.S. Attorney's Office or the trial team familiar with the case. It further criticizes the Government for failing to notify Epstein and Maxwell's victims in advance and for demonstrating a lack of familiarity with the trial record.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the case (1:20-cr-00330-PAE) and grand jury materials.
|
| Jeffrey Epstein | Co-conspirator |
Mentioned in the context of the 'broader Epstein-Maxwell investigation' and his victims.
|
| DAG | Deputy Attorney General |
Filed the motion to unseal alone, without the trial team.
|
| Government's Trial Team | DOJ Lawyers |
Lawyers familiar with the Maxwell case who did not join the motion to unseal.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Second Circuit |
Court of Appeals cited for legal precedent regarding grand jury secrecy.
|
|
| Department of Justice (DOJ) |
Prosecuting body.
|
|
| U.S. Attorney’s Office |
Local federal prosecutor's office (likely SDNY) which did not sign the motion.
|
|
| The Court |
The judge/judicial body overseeing the current case.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Refers to the jurisdiction where the case is filed (Southern District of New York based on case number format).
|
Relationships (2)
Motion filed by DAG alone; trial team did not join or sign.
Government
→
Adversarial/Negligent
→
Victims
Government failed to give advance notice to victims regarding unsealing, causing alarm.
Key Quotes (4)
"The infirmity is that, as the Government has conceded, the Maxwell grand jury materials do not reveal information outside the public domain."Source
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Quote #1
"That motion was not made, nor has it been joined in, by any member of the Government’s trial team—the DOJ lawyers presumably most familiar with the Maxwell case..."Source
DOJ-OGR-00015155.jpg
Quote #2
"The motion was filed by the DAG alone, without any signatory from the U.S. Attorney’s Office in this District."Source
DOJ-OGR-00015155.jpg
Quote #3
"the motion was made without advance notice to Epstein’s and Maxwell’s victims, a fact which, as reviewed below, has alarmed numerous victims."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,010 characters)
Case 1:20-cr-00330-PAE Document 809 Filed 08/11/25 Page 23 of 31
First, as the Second Circuit has explained, the Government’s position is mainly relevant
because it reflects whether there is an ongoing need for grand jury secrecy. See In re Craig, 131
F.3d at 106 (where “the government supports a motion for disclosure, that should serve as a
preliminary indication that the need for secrecy is not especially strong”). But the central
infirmity of this motion to unseal does not concern an ongoing need for secrecy in this case. The
infirmity is that, as the Government has conceded, the Maxwell grand jury materials do not
reveal information outside the public domain.
because it reflects whether there is an ongoing need for grand jury secrecy. See In re Craig, 131
F.3d at 106 (where “the government supports a motion for disclosure, that should serve as a
preliminary indication that the need for secrecy is not especially strong”). But the central
infirmity of this motion to unseal does not concern an ongoing need for secrecy in this case. The
infirmity is that, as the Government has conceded, the Maxwell grand jury materials do not
reveal information outside the public domain.
Second, any argument that the Government’s motion to unseal merits substantial
deference is weakened by a host of irregularities with respect to that motion. That motion was
not made, nor has it been joined in, by any member of the Government’s trial team—the DOJ
lawyers presumably most familiar with the Maxwell case and the broader Epstein-Maxwell
investigation. The motion was filed by the DAG alone, without any signatory from the U.S.
Attorney’s Office in this District. And it was made under circumstances suggestive of haste
rather than reflective deliberation. The motion was three-and-a-half pages in length; there were
no supporting materials filed, under seal or otherwise; the motion did not disclose (or reflect
awareness of) the summary-witness nature of the Maxwell grand jury testimony; and the motion
was made without advance notice to Epstein’s and Maxwell’s victims, a fact which, as reviewed
below, has alarmed numerous victims. Only after the Court inquired on that point was notice to
victims given. See Dkt. 789; Dkt. 796 at 9. Finally, the Government’s highlighting of the grand
jury transcripts did not suggest close familiarity with the Maxwell trial record, because a number
of details that it identified as non-public in fact had been testified to during the trial. See note 16,
supra.
deference is weakened by a host of irregularities with respect to that motion. That motion was
not made, nor has it been joined in, by any member of the Government’s trial team—the DOJ
lawyers presumably most familiar with the Maxwell case and the broader Epstein-Maxwell
investigation. The motion was filed by the DAG alone, without any signatory from the U.S.
Attorney’s Office in this District. And it was made under circumstances suggestive of haste
rather than reflective deliberation. The motion was three-and-a-half pages in length; there were
no supporting materials filed, under seal or otherwise; the motion did not disclose (or reflect
awareness of) the summary-witness nature of the Maxwell grand jury testimony; and the motion
was made without advance notice to Epstein’s and Maxwell’s victims, a fact which, as reviewed
below, has alarmed numerous victims. Only after the Court inquired on that point was notice to
victims given. See Dkt. 789; Dkt. 796 at 9. Finally, the Government’s highlighting of the grand
jury transcripts did not suggest close familiarity with the Maxwell trial record, because a number
of details that it identified as non-public in fact had been testified to during the trial. See note 16,
supra.
23
DOJ-OGR-00015155
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