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Case 1:20-cr-00330-PAE Document 800 _ Filed 08/05/25 Page1of4
U.S. Department of Justice
United States Attorney
Southern District of New York
The Jacob K. Javits Federal Building
26 Federal Plaza, 37th Floor
New York, New York 10278
August 4, 2025
The Honorable Richard M. Berman The Honorable Paul A. Engelmayer
United States District Judge United States District Judge
Southern District of New York Southern District of New York
500 Pearl Street 40 Foley Square
New York, New York 10007 New York, New York 1007
Re: United States v. Jeffrey Epstein,
19 Cr. 490 (RMB)
United States v. Ghislaine Maxwell,
20 Cr. 330 (PAE)
Dear Judges Berman and Engelmayer:
The Government writes respectfully to respond to the Court’s orders, dated July 31, 2025,
directing the Government to provide additional information regarding grand jury materials the
Government has asked the Court to unseal in these cases. (Epstein Dkt. 67; Maxwell Dkt. 797).
In particular, on July 18, 2025, the Government moved the Court to unseal grand jury
transcripts from these cases, subject to appropriate redactions. (Epstein Dkt. 61; Maxwell
Dkt. 785). The Court directed the Government to provide supplemental briefing (Epstein Dkt. 63;
Maxwell Dkt. 789), which the Government submitted on July 29, 2025 (Epstein Dkt. 66; Maxwell
Dkt. 796). In addition, the Court set a schedule whereby the defendants and victims could set out
their positions on or before August 5, 2025. (Epstein Dkt. 63 at 3-4; Maxwell Dkt. 789 at 4).
On July 31, 2025, the Court directed the Government to provide additional information by
August 4, 2025, in particular, in the Epstein case, a letter:
1. Verifying the date(s) of all grand jury presentation(s) in this
case;
2. Providing all exhibits shown to grand jurors;
3. Stating whether the Government moves to unseal the grand
jury exhibits as well as the transcripts;
4, Identifying with specificity the grand jury exhibits that are
not already part of the public record (They may be redacted
for any public release);
DOJ-OGR-00015079