{
  "document_metadata": {
    "page_number": "4",
    "document_number": "70",
    "date": "08/05/25",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 70 Filed 08/05/25 Page 4 of 4\n\nHon. Richard M. Berman, U.S.D.J.\nHon. Paul A. Engelmayer, U.S.D.J.\nAugust 4, 2025\nPage 4 of 4\naffirmed 147 F.2d 336 (5th Cir. 1945) (\"The same jurisdiction that was sought in the beginning continues to exist insofar as the integrity and preservation of the minutia and minutes and proceedings of those steps are concerned. What was done here is evidence and may be advantaged by either party, having in mind, of course, the question of the secrecy of the grand jury proceedings. And the only jurisdiction over such matters is in this court.\"); see also, e.g., Dale v. Bartels, 532 F. Supp. 973, 978-79 (S.D.N.Y. 1982) (ordering limited disclosure of sealed grand jury testimony after entry of a nolle prosequi). However, the fact that Epstein passed away—which was the basis for the entry of the nolle prosequi—is a factor to be considered. See In re Craig, 131 F.3d 99, 106 (2d Cir. 1997) (noting that \"the current status of the principals of the grand jury proceedings and that of their families\" is a factor \"that a trial court might want to consider when confronted with these highly discretionary and fact-sensitive 'special circumstances' motions\").\n\nSeventh, regarding the Government's approach to victim notification of the instant proceedings, as noted in its July 29 submission, the Government has provided notice of the unsealing motions to all but one of the victims who are referenced in the grand jury transcripts at issue in the motions. The Government still has been unable to contact that remaining victim. With respect to victims who are not identified in the grand jury transcripts but who have previously received victim notifications in the Maxwell and Epstein matters, the Government will over the coming days alert those victims to the fact of the unsealing motions.\n\nFinally, in light of the Government's ongoing efforts to ensure that that the interests of victims and other third parties are appropriately considered, as well as the multifaceted nature of these and other relevant proceedings, it may be necessary or appropriate for the Government to modify or supplement the information provided today, and the Government commits to doing so as promptly as practicable.\n\nAs always, the Government is available to answer any questions the Court may have.\n\nRespectfully submitted,\n\nPAMELA J. BONDI\nUnited States Attorney General\nTODD BLANCHE\nDeputy United States Attorney General\nUnited States Department of Justice\n\n/s/ Jay Clayton\nJAY CLAYTON\nUnited States Attorney for the Southern District of New York\n26 Federal Plaza\n37th Floor\nNew York, New York 10278\n\nDOJ-OGR-00000764",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 70 Filed 08/05/25 Page 4 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman, U.S.D.J.\nHon. Paul A. Engelmayer, U.S.D.J.\nAugust 4, 2025\nPage 4 of 4",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "affirmed 147 F.2d 336 (5th Cir. 1945) (\"The same jurisdiction that was sought in the beginning continues to exist insofar as the integrity and preservation of the minutia and minutes and proceedings of those steps are concerned. What was done here is evidence and may be advantaged by either party, having in mind, of course, the question of the secrecy of the grand jury proceedings. And the only jurisdiction over such matters is in this court.\"); see also, e.g., Dale v. Bartels, 532 F. Supp. 973, 978-79 (S.D.N.Y. 1982) (ordering limited disclosure of sealed grand jury testimony after entry of a nolle prosequi). However, the fact that Epstein passed away—which was the basis for the entry of the nolle prosequi—is a factor to be considered. See In re Craig, 131 F.3d 99, 106 (2d Cir. 1997) (noting that \"the current status of the principals of the grand jury proceedings and that of their families\" is a factor \"that a trial court might want to consider when confronted with these highly discretionary and fact-sensitive 'special circumstances' motions\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Seventh, regarding the Government's approach to victim notification of the instant proceedings, as noted in its July 29 submission, the Government has provided notice of the unsealing motions to all but one of the victims who are referenced in the grand jury transcripts at issue in the motions. The Government still has been unable to contact that remaining victim. With respect to victims who are not identified in the grand jury transcripts but who have previously received victim notifications in the Maxwell and Epstein matters, the Government will over the coming days alert those victims to the fact of the unsealing motions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, in light of the Government's ongoing efforts to ensure that that the interests of victims and other third parties are appropriately considered, as well as the multifaceted nature of these and other relevant proceedings, it may be necessary or appropriate for the Government to modify or supplement the information provided today, and the Government commits to doing so as promptly as practicable.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As always, the Government is available to answer any questions the Court may have.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "PAMELA J. BONDI\nUnited States Attorney General\nTODD BLANCHE\nDeputy United States Attorney General\nUnited States Department of Justice",
      "position": "middle"
    },
    {
      "type": "signature",
      "content": "/s/ Jay Clayton",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "JAY CLAYTON\nUnited States Attorney for the Southern District of New York\n26 Federal Plaza\n37th Floor\nNew York, New York 10278",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000764",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Paul A. Engelmayer",
      "Pamela J. Bondi",
      "Todd Blanche",
      "Jay Clayton",
      "Epstein",
      "Maxwell",
      "Craig",
      "Dale",
      "Bartels"
    ],
    "organizations": [
      "United States Department of Justice",
      "United States Attorney General",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 4, 2025",
      "July 29",
      "08/05/25"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 70",
      "DOJ-OGR-00000764"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. [defendant], with the case number 1:19-cr-00490-RMB. The document is signed by Jay Clayton, United States Attorney for the Southern District of New York. The content discusses grand jury proceedings, victim notification, and the government's approach to unsealing motions. The document is typed, with no handwritten text or stamps visible."
}