EPSTEIN
page 6 / 14 . OCR, unverified
special circumstance justifying the public disclosure of grand jury materials. The public's interest
in this investigation persists despite the findings from the Department of Justice and Federal
Bureau of Investigation discussed in the July 5, 2025 memorandum. Given the historical public
interest in this investigation, public disclosure of grand jury materials is justified under the special
circumstances of this case. To the extent this Court's decision is preordained by Pitch, the
government preserves its right to appeal that decision and rely on decisions from the Second and
Seventh Circuit for support.
Finally. many of the rationales supporting grand jury secrecy under Rule 6(e) no longer
apply to this investigation because of Jeffrey Epstein's death. With this grandjury investigation no
longer pending, concerns over the defendant's flight or obstruction or possible collusion among
grand jury witnesses no longer apply. Therefore, the stasis of this investigation further justifies
public disclosure of grand jury transcripts. See In re Pub. First Law Ctr., No. I :24-mc-00215-
TMB-NC, 2024 WL 1885724. at *6 (D. Haw. Apr. 29, 2024) ("[O]ther courts have noted that the
policy rationale to preserve grand jury secrecy is less obvious after the grand jury proceedings
have ended because the primary reasons for grand jury secrecy, namely to 'prevent flight, protect
the jurors, and protect witnesses from being pressured,' are generally less applicable.") (footnote
omitted).
C.
Conclusion
This Court should transfer this petition to the Southern District of New York because this
matter arises out of a judicial proceeding in another district under Rule 6(G). Alternatively. this
Court should grant the government's petition and order the release of grand jury transcripts from
Case 9:25-mc-80920-RLR Document 3 Entered on FLSD Docket 07/23/2025 Page 6 of 14
this investigation because the strong public interest in this investigation constitutes "special
circumstances" justifying release.
Respectfully submitted,
PAMELA J. BONDI
U.S. Attorney General
TODD BLANCHE
Deputy Attorney General
HA 0£NP. O'BYRNt
United States Attorney,
Southern District of Florida
Florida Bar No. 60024
Northeast 4th Street
Miami, Florida 33132-2111
Tel: (305) 961-900 I
Email: Hayden.0Byrne@usdoj.gov
Case 9:25-mc-80920-RLR Document 3 Entered on FLSD Docket 07/23/2025 Page 7 of 14
Case 1:19-cr-O
0-RMB
Document 61
Filed 07
Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
United States of America
V.
Jeffrey Epstein,
Defendant.
GOVERNMENT
EXHIBIT
CASE
NO.
EXHIBIT 1
NO.
I : 19-cr-490 (RMB)
UNITED STATES' MOTION TO UNSEAL GRAND JURY TRANSCRIPTS
At the direction of the Attorney General, the Department of Justice hereby moves the Court
to release grand jury transcripts associated with the above-referenced indictment.
On July 6, 2025, the Department of Justice and Federal Bureau of Investigation issued a
memorandum describing an exhaustive review undertaken of investigative holdings relating to
Jeffrey Epstein (the "Memorandum''). 1 The Memorandum detailed the steps taken by the
Department of Justice and Federal Bureau of Investigation to determine whether evidence existed
that could predicate an investigation into uncharged third parties. As the Memorandum concluded,
no such evidence was uncovered during the review.
Since July 6, 2025. there has been extensive public interest in the basis for the
Memorandum ·s conclusions. While the Department of Justice and Federal Bureau of Investigation
continue to adhere to the conclusions reached in the Memorandum, transparency to the American
public is of the utmost importance to this Administration. Given the public interest in the
investigative work conducted by the Department of Justice and Federal Bureau of Investigation
into Epstein. the Department of Justice moves the Court to unseal the underlying grand jury
https://www.justice.gov/opa/media/ 140700 I /dl?inline.
Case 9:25-mc-80920-RLR Document 3 Entered on FLSD Docket 07/23/2025 Page 8 of 14
Case 1:19-cr-O
0-RMB
Document 61
Filed 07
Page 2 of 4
transcripts in United States v. Epstein, subject to appropriate redactions of victim-related and other
personal identifying infonnation. 2 The Department will work with the United States Attorney's
Office for Southern District of New York to make appropriate redactions of victim-related
information and other personal identifying information prior to releasing the transcripts.
Transparency in this process will not be at the expense of our obligation under the law to protect
victims.
1.
On July 2, 2019, a grand jury sitting in the Southern District of New York returned
an indictment charging Epstein with sex trafficking offenses. See Dkt. No. 2. On August 10, 2019,
while awaiting trial, Epstein committed suicide in his cell in the Metropolitan Correctional Center
in New York City. Soon after, the Court dismissed the indictment. Dkt. No. 52.