Page 1 of 3
[Type text]
September 5, 2025
BY ECF
Honorable Richard M. Berman
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re:
United States v. Jeffrey Epstein,
19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter pursuant to the Court’s order, dated
August 26, 2025 (the “Order”), and in opposition to the motion filed by NBC News on August 13,
2025 (the “Motion”). (Dkt. 78). For the reasons set forth below, as well as those set forth in the
Government’s prior memoranda, the Government submits that the Motion should be denied.
I.
Background
The Motion seeks to unseal the names of two individuals referenced in a letter filed by the
Government on July 16, 2019 (the “July 2019 Letter” or Dkt. 23). The Government will refer to
the individual referenced on the first page of the July 2019 Letter in the paragraph beginning
“First” as “Individual-1” and the individual referenced on the same page in the paragraph
beginning “Second” as “Individual-2.” (See Dkt. 23 at 1).
Pursuant to the Order, on August 26, 2025, the Government notified Individual-1 and
Individual-2 of the Motion and the Order.
On August 29, 2025, the Government received a letter from counsel for Individual-1. The
letter, which is attached hereto as Exhibit A, expressed Individual-1’s opposition to the Motion.
On September 5, 2025, the Government received an email from counsel for Individual-2.
The email, which is attached as Exhibit B, expressed Individual-2’s opposition to the Motion.1
1 Because Exhibits A and B both contain personal identifying information for Individual-1 or
Individual-2 and describe certain matters that are highly personal and sensitive, the Government
respectfully submits that sealing of both exhibits is appropriate. See, e.g., United States v. Amodeo,
71 F.3d 1044, 1051 (2d Cir. 1995) (The “privacy interests of innocent third parties” should “weigh
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 79 Filed 09/05/25 Page 1 of 3