DOJ-OGR-00015089.jpg

738 KB

Extraction Summary

3
People
2
Organizations
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Locations
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Events
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Relationships
3
Quotes

Document Information

Type: Legal filing / court brief
File Size: 738 KB
Summary

Page 3 of a legal filing (Document 803) in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text argues the legal standards for unsealing grand jury records, citing the precedent 'In re Craig' and listing the specific factors courts must weigh when considering disclosure. The document footer indicates it was prepared by defense counsel (Markus/Moss) and bears a DOJ production stamp.

People (3)

Name Role Context
Harry Dexter White Historical Figure / Government Employee
Mentioned in the cited case 'In re Craig' as a high-ranking government employee and suspected communist spy whose gra...
Markus Attorney
Listed in footer 'MARKUS/MOSS', likely defense counsel David Oscar Markus.
Moss Attorney
Listed in footer 'MARKUS/MOSS', likely defense counsel.

Organizations (2)

Name Type Context
Second Circuit
Cited as the court that affirmed the denial of the petition in 'In re Craig'.
DOJ
Department of Justice, indicated in footer stamp 'DOJ-OGR-00015089'.

Timeline (1 events)

2025-08-05
Filing of Document 803 in Case 1:20-cr-00330-PAE
Court

Key Quotes (3)

"the discretion of a trial court in deciding whether to make public the ordinarily secret proceedings of a grand jury investigation is one of the broadest and most sensitive exercises of careful judgment that a trial judge can make."
Source
DOJ-OGR-00015089.jpg
Quote #1
"In re Craig involved a petition by a doctoral candidate to unseal the nearly 50- year-old grand jury testimony of a high-ranking government employee, Harry Dexter White"
Source
DOJ-OGR-00015089.jpg
Quote #2
"Those factors include... (i) the identity of the party seeking disclosure; (ii) whether the defendant to the grand jury proceeding or the government opposes the disclosure"
Source
DOJ-OGR-00015089.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,980 characters)

Case 1:20-cr-00330-PAE Document 803 Filed 08/05/25 Page 3 of 9
release of grand jury records is appropriate even outside the boundaries of Rule
6(e)(3). In re Craig, 131 F.3d at 102. Importantly, “the discretion of a trial court in
deciding whether to make public the ordinarily secret proceedings of a grand jury
investigation is one of the broadest and most sensitive exercises of careful judgment
that a trial judge can make.” Id. at 104.
In re Craig involved a petition by a doctoral candidate to unseal the nearly 50-
year-old grand jury testimony of a high-ranking government employee, Harry Dexter
White, based on historical interest in White’s suspected role as a communist spy. The
court in In re Craig denied the petition to unseal. On appeal, the Second Circuit
affirmed the trial court’s denial of the petition, finding that the court did not abuse
its discretion when it found that sufficiently exceptional circumstances did not exist
to warrant disclosure. Id. at 100-01, 107.
In affirming the lower court’s denial of the motion to unseal, the Second Circuit
acknowledged historical interest as a potential basis for disclosure and offered a non-
exhaustive list of factors that a trial court might consider when confronted with
ruling on a motion to unseal. Id. at 105-06. Those factors include, but are not limited
to:
(i) the identity of the party seeking disclosure; (ii) whether
the defendant to the grand jury proceeding or the government
opposes the disclosure; (iii) why disclosure is being sought in
the particular case; (iv) what specific information is being
sought for disclosure; (v) how long ago the grand jury
proceedings took place; (vi) the current status of the principals
of the grand jury proceedings and that of their families; (vii)
the extent to which the desired material—either permissibly
or impermissibly—has been previously made public; (viii)
whether witnesses to the grand jury proceedings who might
MARKUS/MOSS
3
DOJ-OGR-00015089

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