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Case 1:20-cr-00330-PAE Document 804 Filed 08/06/25 Page 10 of 27

BSF

A. Why Disclosure Is Being Sought in Particular Case

Grand jury secrecy may serve legitimate purposes in ordinary cases, but this is no ordinary
case. In addition to the public interest that the Government identifies, Epstein Dkt. No. 66 at 4–5,
disclosure of the grand jury transcripts in this case serves the interest of Epstein’s and Maxwell’s
victims in bringing light to Epstein’s and Maxwell’s horrific crimes. This transparency and
accountability is a form of justice. Epstein is the world’s most notorious sex offender, and his
crimes span decades, with thousands of victims. Epstein was a calculated predator who preyed on
minors and young women using wealth, deceit, and manipulation. Maxwell, his righthand woman,
played a central role in recruiting, grooming, and trafficking Epstein’s victims, oftentimes
participating in the abuse. Her participation, and the complicity and participation of others,
enabled Epstein to conduct a decades-long sex-trafficking scheme.

Given the magnitude and abhorrence of Epstein and Maxwell’s crimes, unsealing the grand
jury transcripts is not just appropriate, it is necessary to understand the full scope of the abuse and
those who enabled it. For years, victims of Epstein’s and Maxwell’s crimes have been silenced,
fearful of the repercussions of exposing the many powerful individuals in Epstein’s network, many
of whom have not yet been named or investigated. Unsealing the grand jury transcripts would
allow additional important information to emerge without requiring the victims to expose
themselves to the same ridicule, retaliation, and humiliation they would face if they were the ones
to expose such information. The Government itself acknowledged that there are “over one
thousand victims,” ³ yet only a small fraction—approximately one-fifth—have received
compensation, underscoring the continuing lack of full accountability for Epstein, Maxwell, and
their co-conspirators. The interests of the victims should therefore weigh in favor of disclosure.
See Matter of Aiani v. Donovan, 98 A.D.3d 972, 974 (2d Dep’t 2012) (ordering disclosure of
banking records requested in connection with grand jury proceedings based on the interests of the
victims).

B. Whether Witnesses to the Grand Jury Transcripts Who Might Be Affected by
Disclosure Are Still Alive

This factor considers whether individuals who may be affected by the disclosure of grand
jury materials may be adversely impacted by unsealing. This case presents a rare and compelling
circumstance where the victims seek transparency, not secrecy. In In re National Security Archive,
for example, where the proceedings held substantial historical importance and the living witnesses
did not express any objection to the release, the Court found that the release of grand jury testimony
was appropriate. 2008 WL 8985358, at *1–2 (S.D.N.Y. Aug. 26, 2008). The victims represented
by the undersigned counsel who are still alive do not just passively support unsealing, but

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³ See U.S. Dep’t of Justice, Federal Bureau of Investigation, Memorandum (July 6, 2025),
https://www.justice.gov/opa/media/1407001/dl?inline.
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