gov.uscourts.nysd.518649.75.0.pdf

[Type text] August 8, 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 Judge Engelmayer’s Order dated August 5, 2025, and Judge Berman’s Order dated August 6, 2025. In addition to seeking to unseal the grand jury transcripts, the Government moves to unseal the Maxwell and Epstein grand jury exhibits subject to appropriate redactions of victim-related and other personal identifying information. As there are parties whose names appear in the grand jury exhibits but did not appear in the grand jury transcripts, the Government is undertaking to notify such parties to the extent their names appear in grand jury exhibits that were not publicly admitted at the Maxwell trial (and they were not already notified in connection with the request to unseal the grand jury transcripts). The Government respectfully requests to update the Court following those notifications by August 14, 2025, and requests that the Court await that update before unsealing any of the grand jury exhibits, to the extent the Court is otherwise inclined to do so. In conjunction with this letter, the Government will submit sealed, ex parte submissions clarifying which portions of the grand jury exhibits in the Maxwell and Epstein matters have been made public. In making this assessment, the Government has compared the grand jury exhibits against the trial record and exhibits in the Maxwell trial, as well as against any publicly filed civil complaints identified by the Government that were filed by certain victims, as explained in further detail in the Government’s sealed, ex parte submissions.1 1 Many civil complaints were filed in federal and state courts on behalf of victims identified solely as “Jane Doe” or by initials that may or may not be the initials of the plaintiffs in those actions, and therefore the Government cannot attribute with certainty to whom the statements or allegations in those anonymized complaints can be attributed. If the Government identifies additional materials on public dockets that make such attribution possible, it promptly will notify the Court. The Jacob K. Javits Federal Building 26 Federal Plaza, 37th Floor New York, New York 10278 U.S. Department of Justice United States Attorney Southern District of New York Case 1:19-cr-00490-RMB Document 75 Filed 08/08/25 Page 1 of 2

Hon. Richard M. Berman Hon. Paul A. Engelmayer August 8, 2025 Page 2 of 2 The Government will also today submit to Judge Berman under seal and ex parte a version of the Epstein grand jury transcripts that specifically identifies which information in the transcripts is, as far as the Government is aware, publicly available. This approach is in line with that taken by the Government with respect to the Maxwell grand jury transcripts submitted to Judge Engelmayer on August 4, 2025 (20 Cr. 330, Dkt. 800). As always, the Government is available to answer any questions the Court may have. Respectfully submitted, PAMELA J. BONDI United States Attorney General TODD BLANCHE Deputy United States Attorney General United States Department of Justice /s/ Jay Clayton JAY CLAYTON United States Attorney for the Southern District of New York 26 Federal Plaza 37th Floor New York, New York 10278 Case 1:19-cr-00490-RMB Document 75 Filed 08/08/25 Page 2 of 2