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New York Office
By Appointment Only
September 5, 2025
BY ECF:
Hon. Richard M. Berman
United States District Court
Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl St.,
Courtroom 17B
New York, NY 10007
RE: United States of America v. Jeffrey Epstein, Case No. 19-CR-490 (RMB)
Dear Judge Berman:
Pursuant to the August 26, 2025 Order of this Court, undersigned counsel for Epstein victims
submits this response objecting to the unsealing requested by NBC. Consistent with the reasoning
of this Court in its August 20, 2025 Order, particularly the discussion at pages 8-9, it is imperative
that these names remain sealed, as disclosure poses a real threat to victims’ safety and privacy and
would be in violation of 18 U.S.C. § 3771, the Crime Victim’s Rights Act’s guarantees of fairness,
privacy, conferral, and protection.
The letter submitted to the Court by NBC indicates that the network does not intend to reveal
sensitive information about victims, and as such, it would be the hope of the undersigned that the
request is mooted by nature of this correspondence. Our position has likewise been expressed to
the Department of Justice.
Respectfully Submitted,
EDWARDS HENDERSON, PLLC
By:
Bradley J. Edwards
Brittany N. Henderson
425 N. Andrews Ave., Suite 2
MEMO ENDORSED
Docket and file.
9/9/2025
Case 1:19-cr-00490-RMB Document 80 Filed 09/09/25 Page 1 of 2