UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In re Application of the United States for a Disclosure Order in connection with Grand Jury Investigation USAO Ref No. 2018R01618 in the United States District Court for the Southern District of New York Ex Parte Sealed Application for Grand Jury Disclosure Order 19 Misc. 0586 The United States of America (the "Government"), by its attorney, Geoffrey S. Berman, United States Attorney for the Southern District of New York, Associate United States Attorney, of counsel, respectfully moves this Court pursuant to Federal Rule of Criminal Procedure 6(c)(3)(E)(i) & 6(e)(3)(F) for an order authorizing disclosure of certain grand jury matters in aid of a continuing investigation into conduct by associates of Jeffrey Epstein relating to alleged sex trafficking of minors by Jeffrey Epstein, and other offenses, and possible forfeitures or injunctive relief. This application relates specifically to a series of wills and trusts created by Jeffrey Epstein over the period of approximately 2001 to 2018 that were intended to receive most (if not all) of Jeffrey Epstein's assets, including potentially forfeitable assets, and pursuant to which substantial payments would be made over time to individual beneficiaries, including individuals who may be of interest in the ongoing investigation. By this application we request authorization to disclose certain trust agreements and related documents to a trusts and estates expert we have retained to advise us in this area of law, and to attorneys in our Civil Division who would represent the Government in any litigation that may appear advisable to assert Government interests concerning these matters. As discussed more fully below, on December 20, 2019, the Honorable Denise Cote entered a disclosure order, similar in form to the order requested herein, relating to an earlier set of trust and estate documents which we had received in this EFTA00086220