EPSTEIN
page 4 / 14 . OCR, unverified
Alternatively, if, under applicable law, there is no legal basis to transfer the Petition, the
Government should clearly state the same.
It is hereby ORDERED that the Government must file a supplemental brief addressing the
above-described issues. The Government's brief shall not exceed ten pages and shall be submitted
by no later than 3 p.m. on Sunday, July 20, 2025.
DONE AND ORDERED in Chambers, West Palm Beach, Florida, this 19th day of July,
2025.
ROBIN L. ROSENBRG ( / '
UNITED STATES DISTRieT JUDGE
==================== END OF Court Records__In re Grand Jury 05-02 (WPB) & 07-103 (WPB), No. 925-mc-80920 (S.D. Fla. 2025)__002.txt ====================
==================== DOCUMENT: Court Records__In re Grand Jury 05-02 (WPB) & 07-103 (WPB), No. 925-mc-80920 (S.D. Fla. 2025)__003.txt ====================
METADATA_SOURCE: Court RecordsIn re Grand Jury 05-02 (WPB) & 07-103 (WPB), No. 925-mc-80920 (S.D. Fla. 2025)
METADATA_FILENAME: 003.pdf
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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 those persons identified in Rule 6(e)(3)(F)
a reasonable opportunity to appear and be heard.
Case 9:25-mc-80920-RLR Document 3 Entered on FLSD Docket 07/23/2025 Page 2 of 14
Fed. R. Crim. P. 6(e)(3)(G) (emphasis added).
This Petition to Disclose (filed on July 18, 2025) arises out of two highly publicizedjudicial
proceedings in the Southern District of New York: the indictment and criminal prosecution of
Jeffrey Epstein, United States v. Epstein, I: I 9-CR-490 (S.D.N.Y.), and the subsequent federal
criminal indictment, trial, and conviction of Ghislaine Maxwell in the Southern District of New
York, United States v. Maxwell, I :20-CR-330 (S.D.N.Y.). Indeed, the relief sought in this petition
is ancillary to the relief sought in those cases. Motions seeking identical relief were
contemporaneously filed in the Southern District of New York on July 18, 2025. 1 Rule 6(e)(3)(i)
requires that this petition "must be filed in the district where the grand jury convened." As a result,
this petition was also filed in this Court.
The only judicial proceedings are in the Southern District of New York. In the July 19,
2025 Order Requiring Supplemental Briefing, the Court defined the Southern District of Florida
('·SDFL") grand jury proceedings as the "Florida Proceedings,'' and United States v. Maxwell, No.
I :20-CR-330 (S.D.N.Y.) and United States v. Epstein, No. I: I 9-CR-490 (S.D.N.Y.) as the "New
York Proceedings.'' But the "Florida Proceedings" were not judicial proceedings-they were grand
jury proceedings. To that point, the Eleventh Circuit in Pitch distinguished between grand jury and
judicial proceedings: "The grand jury is by design an institution independent from the Judicial
Branch. Accordingly, the district court neither presides over the grand jury nor monitors its
proceedings. In fact, Rule 6 does not permit the district judge to be present in the grand jury room
at all." Pitch v. United States, 953 F.3d 1226, 1237 (11th Cir. 2020) (en bane) (cleaned up); see