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December 8, 2025
BY ECF
Honorable Richard M. Berman
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Honorable Paul A. Engelmayer
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
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 respectfully submits this letter in response to Your Honors’ respective
Orders, the November 26, 2025, Order in United States v. Jeffrey Epstein, 19 Cr. 490 (RMB), Dkt.
87, and the November 24, 2025 Order in United States v. Ghislaine Maxwell, 20 Cr. 330 (PAE),
Dkt. 811. The Government submits this response to the Orders jointly as it believes there is
substantial overlap in the issues raised in the respective Orders. As a threshold matter, the
Department continues to view victim privacy as paramount in these cases, including in connection
with its efforts to comply with the Act, and the Department recognizes and appreciates the Courts’
focus on victim privacy.1 Several of the victims who have made submissions in response to the
1 As noted in the Government’s submission to Judge Berman, the claims raised by Mr. Edwards
in his letter submitted to each of Your Honors regarding the Department’s efforts to protect victim
privacy are incorrect. See United States v. Jeffrey Epstein, 19 Cr. 490 (RMB), Dkt. 88. A copy of
the Department’s submission clarifying this point to Judge Berman is attached as Exhibit A.
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 91 Filed 12/08/25 Page 1 of 4