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Case 1:20-cr-00330-PAE Document 804 Filed 08/06/25 Page 11 of 27

BSF

affirmatively support unsealing, subject to appropriate redactions to protect their personal privacy.
Their consent to disclosure should weigh in favor of unsealing under this factor. Further, because
the Government intends to redact the names and identifying information of the victims, there is no
risk that the privacy of the victims will be jeopardized. In re Kutler, 800 F. Supp. 2d 42, 50 (D.D.C.
2011) (procedures for reviewing transcripts to protect named individuals as needed "allay any
remaining privacy concerns").

2. The Court Should Assess the Appropriateness of the Redactions.

The grand jury transcripts should be released subject to narrowly tailored redactions of the
names, likenesses, and identifying information of the victims. The Court should not, however,
rubber stamp redactions to withhold from the public "information related to third parties who
neither have been charged or alleged to be involved in the crimes with which Epstein and Maxwell
were charged," Epstein Dkt. No. 66 at 7. Any effort to redact third party names smacks of a cover
up. The Government does not elaborate on what protocol it is using to redact other "third party"
names or which types of individuals it seeks to protect in this way. To the extent the Government
for some reason seeks to redact the names of other Epstein and Maxwell affiliates on the basis that
these individuals "neither have been charged or alleged to be involved" in their crimes, the Court
should exercise its independent authority to ensure that any redactions are tailored to serve
compelling interests. See generally Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (even if
materials are not considered judicial documents to which a presumption of public access applies,
"a court must still articulate specific and substantial reasons for sealing such material").

A. Redactions of the Names and Identifying Information of the Victims Is
Appropriate.

The privacy interests of Ms. Farmer and other victims (as victims of sex abuse and human
trafficking) are strong. In Giuffre v. Maxwell, Judge Preska repeatedly recognized the "gravity of
the privacy interests" of "victims of Jeffrey Epstein's sexual abuse." Giuffre v. Maxwell, 2020
U.S. Dist. LEXIS 221599, at *16 (S.D.N.Y. Nov. 25, 2020). The Court explained that "[t]hose
interests are particularly acute given that the psychological and emotional wellbeing of survivors
of alleged sexual assaults may be implicated by such a broad disclosure." Giuffre v. Dershowitz,
2020 WL 5439623, at *2 (S.D.N.Y. Sept. 9, 2020). And "[t]hose interests weigh no less heavily"
where "it is law enforcement seeking modification of the protective order instead of a private
litigant." Giuffre v. Maxwell, 2020 U.S. Dist. LEXIS 221599, at *16. In Doe 1 v. JP Morgan
Chase Bank, N.A., Judge Rakoff recently found that the privacy interest of a victim of Epstein
justified sealing because "[p]rotecting the identity of sexual assault survivors and the details of
their assaults is traditionally considered private and has been widely recognized as a compelling
reason to limit public access to [even] judicial documents." 742 F. Supp. 3d 387, 397 (S.D.N.Y.

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