803 [DOJ-OGR-00015087—DOJ-OGR-00015095]

Case 1:20-cr-00330-PAE Document 803 _ Filed 08/05/25 Page1of9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, 20-CR-330 (PAE) vs. GHISLAINE MAXWELL. / GHISLAINE MAXWELL’S RESPONSE IN OPPOSITION TO GOVERNMENT’S MOTION TO UNSEAL GRAND JURY TRANSCRIPTS Although the government did not oppose allowing the defense to review the grand jury material to assess whether to object to its release, the Court denied that request. As a result, Ghislaine Maxwell has not seen the material and cannot take an informed position. Given that she is actively litigating her case and does not know what is in the grand jury record, she has no choice but to respectfully oppose the government’s motion to unseal it. I. INTRODUCTION Jeffrey Epstein is dead. Ghislaine Maxwell is not. Whatever interest the public may have in Epstein, that interest cannot justify a broad intrusion into grand jury secrecy in a case where the defendant is alive, her legal options are viable, and her due process rights remain. When Epstein died, prosecutors from the Southern District of New York pivoted and made Maxwell the face of his crimes. She became the scapegoat and the only person the government could put on trial. She was convicted in a media firestorm of false reporting and mischaracterization of evidence. Now, with her case pending before the Supreme Court, the government seeks to unseal untested, MARKUS/MOSS 1 DOJ-OGR-00015087