In re Grand Jury 05-02 & 07-103: Filing 003

Case 9:25-mc-80920-RLR Document 3 Entered on FLSD Docket 07/23/2025 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. ---------- FILED BY~,r«:,_ D.C. IN RE: Grand Jury 05-02 (WPB) 07-103(WPB) JUL 2 0 2025 / ANGELA E. NOBLE --------------- CLERK U.S. DIST. CT. S.O. OF FLA, - W.P.B. UNITED STATES' RESPONSE TO ORDER ON SUPPLEMENTAL BREIFING Consistent with the Court's July 19, 2025 order, the United States files this supplemental brief addressing (I) the government's request to transfer this petition to the Southern District of New York; and (2) the government's request to unseal grand jury documents. A. The Court Should Transfer this Petition to the Southern District of New York In response to the second set of questions posed in the July 19, 2025 Order, the government responds as fol lows: (I) this petition is eligible for transfer to the Southern District of New York; (2) Rule 6(e)(3)(G) permits the transfer since the only judicial proceedings were in the Southern District of New York and not in the Southern District of Florida; and (3) this petition to disclose arose out of the highly-publicized indictment of Jeffrey Epstein and subsequent federal criminal trial of Ghislaine Maxwell in the Southern District of New York. Further, this petition is ancillary to the New York Proceedings seeking the same relief. The petition is eligible for transfer to the Southern District of New York under Rule 6(e)(3)(G), which states the following: (G) If the petition to disclose arises out of a judicial proceeding in another district, the petitioned court must transfer the petition to the other court unless the petitioned court can reasonably determine whether disclosure is proper. If the petitioned court decides to transfer, it must send to the transferee court the material sought to be disclosed, iffeasible, and a written evaluation of the need for continued grand-jury secrecy. The transferee court must afford thos