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Case 1:20-cr-00330-PAE Document 789 Filed 07/22/25 Page 3 of 4

The Government's motion does not adequately address these factors. The Court accordingly directs the Government to file a memorandum of law, no later than Tuesday, July 29, 2025, addressing with specificity these and any other factors that the Government views as germane to its application. The memorandum of law is to be no more than 25 pages, double spaced. In light of grand jury secrecy and victim-related issues and other personal identifying information concerns, the Government is authorized to file, on the public record, a redacted version, and to file under seal the memorandum in unredacted form. The Court also directs the Government to state in the memorandum whether, before filing the instant motion, counsel for the Government reviewed the Maxwell grand jury transcripts and whether the Government provided notice to the victims of the motion to unseal.

Following the Court's ruling on the motion, the Court will invite the Government's input as to whether, and to what extent, the redactions in its memorandum remain warranted.

Grand jury transcripts: The Court has not received the grand jury transcripts that the Government seeks to unseal. The Court directs the Government to submit to the Court under seal the following materials no later than Tuesday, July 29, 2025: (1) an index of Maxwell grand jury transcript materials, including a brief summary, the number of pages, and dates; (2) a complete set of Maxwell grand jury transcripts; (3) a complete proposed redacted set of Maxwell grand jury transcripts (i.e., the transcripts in the form that the Government proposes to release them); and (4) a description of any other Maxwell grand jury materials, including, but not limited to, exhibits.

140 S. Ct. 597 (2020); Pitch v. United States, 953 F.3d 1226, 1241 (11th Cir. 2020) (en banc); United States v. McDougal, 559 F.3d 837, 841 (8th Cir. 2009); In re Grand Jury 89-4-72, 932
F.2d 481, 488 (6th Cir. 1991).
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