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Case 1:19-cr-00490-RMB BSF Document 72 Filed 08/05/25 Page 1 of 5 I BOIES SCHILLER FLEXNER MEMO ENDORSED Sigrid McCawley Telephone: (954) 377-4223 Email: smccawley®bsfilp.com August 5,2025 Hon. Richard M. Berman U.S. District Court for the Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Hon. Paul A. Engelmayer U.S. District Court of the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Dockci and file. SO ORDERED: 5 25 P.44.4,as Richard M. Berman, US.DJ. Re: Unsealing of Grand Jury Transcripts in CS. v. Epstein, 19-cr-490 (RMB) and U.S. v. Maxwell, 20-cr-330 (PAE) Dear Judges Berman and Engelmayer, We write on behalf of in response to the belated notice that we received from the Department of Justice on July 25, 2025, advising that the Court is seeking letters on behalf of victims setting out their positions on the proposed disclosures of Jeffrey Epstein's and Ghislainc Maxwell's grand jury transcripts.' By the Government's admission, "over one thousand victims" suffered from Epstein's and Maxwell's actions. To date, however, the combined forces of our country's law enforcement agencies have only ever arrested these two individuals in connection with crimes committed against countless young women and girls, and the Government's recent suggestion that no further criminal investigations are forthcoming is a cowardly abdication of its duties to protect and serve.2 is a survivor of Epstein's and Maxwell's crimes and testified at Maxwell's trial. While the undersigned counsel has at various times, represented hundreds of victims of Epstein and Maxwell aside from MM, the Department of Justice's notice did not identify the specific victims whose names, likenesses, or information may be subject to disclosure. 2 Of those two, Epstein escaped justice through his apparent suicide, and Maxwell is now, to the victims' horror, herself attempting to esc

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