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Case 1:19-cr-00490-RMB Document 72 Filed 08/05/25 Page 4 of 5

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 I 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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