Motion to Unseal Grand Jury Testimony in Maxwell Case (Nov 2025)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA - v. - GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (PAE) UNITED STATES’ MOTION FOR EXPEDITED RULING TO UNSEAL GRAND JURY TRANSCRIPTS AND EXHIBITS AND MODIFY PROTECTIVE ORDER Pursuant to H.R. 4405, the Epstein Files Transparency Act (the “Act”), and at the direction of the Attorney General, the Department of Justice respectfully files this motion asking the Court for an expedited ruling to unseal the grand jury transcripts and exhibits and to modify the protective order associated with the above-referenced indictment. The Department of Justice previously moved the Court to unseal the grand jury transcripts and exhibits in this case, citing the “extensive public interest” in the basis for conclusions in a July 6, 2025, Memorandum issued by the Department of Justice and Federal Bureau of Investigation. Dkt. 785. The Court denied the motion, concluding that neither Federal Rule of Criminal Procedure 6(e) nor “special circumstances” authorized unsealing the grand jury materials. Dkt. 809. On November 19, 2025, Congress nearly unanimously passed,1 and the President signed the Act. Subject to certain enumerated exceptions, the Act requires the Attorney General, within thirty days after enactment, to “make publicly available . . . all unclassified records, documents, communications, and investigative materials in the possession of the Department of Justice, 1 The Act passed the House by a vote of 427 to 1; the Act passed the Senate unanimously. See Scott Wong, et al., Congress passes bill to force the release of the Epstein files, NBC News (Nov, 19, 2025, 10:06 AM EST), https://www.nbcnews.com/politics/congress/house-bill-force-release-epstein-files-bipartisan-vote- rcna244301. Case 1:20-cr-00330-PAE Document 810 Filed 11/24/25 Page 1 of 8 2 including the Federal Bureau of Investigation and United States Attorneys’ Offices” that relate