{
  "document_metadata": {
    "page_number": "3",
    "document_number": "64",
    "date": "07/25/25",
    "document_type": "Letter Motion",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 64 Filed 07/25/25 Page 3 of 4\n\nNATIONAL SECURITY COUNSELORS\n1451 ROCKVILLE PIKE, SUITE 250\nROCKVILLE, MD 20852\nTELEPHONE: (501) 301-4NSC (4672)\nFACSIMILE: (240) 681-2189\n\nKEL MCCLANAHAN, ESQ., EXECUTIVE DIRECTOR (admitted in DC, NY, WA)\nEMAIL: KEL@NATIONALSECURITYLAW.ORG\nBRADLEY P. MOSS, ESQ., DEPUTY EXECUTIVE DIRECTOR (admitted in DC, IL)\n\n25 July 2025\n\nHon. Richard M. Berman\nUnited States District Court for the Southern District of New York\nThurgood Marshall Courthouse\n40 Foley Square\nNew York, NY 10007\n\nRe:    United States v. Epstein, Case No. 19-Cr-490\n\nDear Judge Berman:\n\nOn behalf of MSW Media, Inc. (\"MSW Media\"), I respectfully submit this letter motion to intervene in the above-captioned case for the purposes of partially supporting and partially opposing the Government's motion to unseal the transcripts of grand jury testimony in this case, filed as Docket No. 61.\n\nMSW Media (https://mswmedia.com/) operates numerous podcasts and blogs about federal government operations, including Mueller She Wrote, SpyTalk, Daily Beans, and Jack. It clearly qualifies as a representative of the news media.\n\nMSW Media has standing to intervene in this case for the following reason. On 17 July 2025, after President Donald Trump publicly instructed Attorney General Pam Bondi to seek the Court's permission to release \"any and all pertinent Grand Jury testimony, we filed a Freedom of Information Act (\"FOIA\") request with the Department of Justice (\"DOJ\") for transcripts of all grand jury testimony from this case and United States v. Maxwell, No. 20-330 (S.D.N.Y.). We are concerned with the modifier \"pertinent\" in President Trump's instruction, and that concern seemed vindicated when the Government advised this Court that it intended to \"make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts.\" (Dkt. #61 at 2 (emphasis added).)\n\nTo be clear, we have no interest in victim-related information, and this Motion does not pertain to that information. However, we do have concerns that the Government seems to be implicitly seeking this Court's permission to withhold other personally identifiable information, such as information about the former defendant's partners in crime or clients. Accordingly, while we join the Government in requesting that these transcripts be released, we accordingly make this narrow independent request to the Court: Please do not weigh in on the appropriateness of withholding personally identifiable information unrelated to victims. We intend to litigate this FOIA request if necessary, and the question of whether such information may be properly\n\nDOJ-OGR-00000743",
  "text_blocks": [
    {
      "type": "printed",
      "content": "NATIONAL SECURITY COUNSELORS\n1451 ROCKVILLE PIKE, SUITE 250\nROCKVILLE, MD 20852\nTELEPHONE: (501) 301-4NSC (4672)\nFACSIMILE: (240) 681-2189",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "KEL MCCLANAHAN, ESQ., EXECUTIVE DIRECTOR (admitted in DC, NY, WA)\nEMAIL: KEL@NATIONALSECURITYLAW.ORG\nBRADLEY P. MOSS, ESQ., DEPUTY EXECUTIVE DIRECTOR (admitted in DC, IL)",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "25 July 2025",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman\nUnited States District Court for the Southern District of New York\nThurgood Marshall Courthouse\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re:    United States v. Epstein, Case No. 19-Cr-490",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Berman:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On behalf of MSW Media, Inc. (\"MSW Media\"), I respectfully submit this letter motion to intervene in the above-captioned case for the purposes of partially supporting and partially opposing the Government's motion to unseal the transcripts of grand jury testimony in this case, filed as Docket No. 61.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "MSW Media (https://mswmedia.com/) operates numerous podcasts and blogs about federal government operations, including Mueller She Wrote, SpyTalk, Daily Beans, and Jack. It clearly qualifies as a representative of the news media.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "MSW Media has standing to intervene in this case for the following reason. On 17 July 2025, after President Donald Trump publicly instructed Attorney General Pam Bondi to seek the Court's permission to release \"any and all pertinent Grand Jury testimony, we filed a Freedom of Information Act (\"FOIA\") request with the Department of Justice (\"DOJ\") for transcripts of all grand jury testimony from this case and United States v. Maxwell, No. 20-330 (S.D.N.Y.). We are concerned with the modifier \"pertinent\" in President Trump's instruction, and that concern seemed vindicated when the Government advised this Court that it intended to \"make appropriate redactions of victim-related information and other personal identifying information prior to releasing the transcripts.\" (Dkt. #61 at 2 (emphasis added).)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To be clear, we have no interest in victim-related information, and this Motion does not pertain to that information. However, we do have concerns that the Government seems to be implicitly seeking this Court's permission to withhold other personally identifiable information, such as information about the former defendant's partners in crime or clients. Accordingly, while we join the Government in requesting that these transcripts be released, we accordingly make this narrow independent request to the Court: Please do not weigh in on the appropriateness of withholding personally identifiable information unrelated to victims. We intend to litigate this FOIA request if necessary, and the question of whether such information may be properly",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000743",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Donald Trump",
      "Pam Bondi"
    ],
    "organizations": [
      "National Security Counselors",
      "MSW Media, Inc.",
      "Department of Justice"
    ],
    "locations": [
      "Rockville, MD",
      "New York, NY"
    ],
    "dates": [
      "25 July 2025",
      "17 July 2025"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 64",
      "Docket No. 61",
      "No. 20-330 (S.D.N.Y.)",
      "DOJ-OGR-00000743"
    ]
  },
  "additional_notes": "The document is a letter motion filed on behalf of MSW Media, Inc. in the case United States v. Epstein. The letter is dated July 25, 2025, and is addressed to Hon. Richard M. Berman. The document is page 3 of 4."
}