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December 1, 2025
BY ECF
The Honorable Richard M. Berman
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
United States v. Jeffrey Epstein,
19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter in response to the Court’s November 26,
2025, Order. Dkt. 87. As an initial matter, the Department responds to the claims by Mr. Edwards
that the Department failed to protect victim-identifying information—a concern that has been, and
continues to be, paramount to the Department in this matter. The Government then respectfully
responds to the Court’s questions below to the best of its ability at this early juncture in its review
of potentially responsive materials pursuant to the directives of H.R. 4405, the Epstein Files
Transparency Act (the “Act”).
Mr. Edwards notes a November 12, 2025 release of documents by Congress and cites to
several instances of victims reaching out to him with (understandably) serious concern about being
identified publicly. Mr. Edwards criticizes the efforts of Congress to protect their identities.
Mr. Edwards then inaccurately contends that: “Of much greater concern is the redaction process,
or complete lack thereof, being applied by the Department of Justice.” Dkt. 87 at 4. The first time
the Government learned that Mr. Edwards’s clients had concerns about documents released by
Congress was in Mr. Edwards’s November 25, 2025 letter, which he simultaneously submitted to
the Court. To this point, Mr. Edwards has not provided specifics of the documents at issue. As
soon as the Government learned of the concern from these victims, it contacted Mr. Edwards, and
we are scheduled to confer later today. The Government is committed to working in good faith
with Mr. Edwards to collect more information and to protect victim identities and interests, but
Mr. Edwards’s sweeping characterization of the procedures applied by the Department to date is
inaccurate. The Government will update the Court after further conferring with counsel.
With regard to the Court’s questions, the Government relies principally upon its submission
to Judge Engelmayer, which is attached. See United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE)
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 88 Filed 12/01/25 Page 1 of 2