{
  "document_metadata": {
    "page_number": "5",
    "document_number": "66",
    "date": "07/29/25",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 66 Filed 07/29/25 Page 5 of 10\n\nnature of the instant request, it is also (like the Court) faced with a broad public interest in the underlying proceedings.\n\n2. Whether the Defendant to the Grand Jury Proceeding or the Government Opposes the Disclosure\n\nThe second factor asks whether the defendant or the Government opposes public disclosure of grand jury materials. See In re Craig, 131 F.3d at 106; see also Lawyers' Committee for 9/11 Inquiry Inc. v. Garland, 43 F.4th 276, 285-86 (2d Cir. 2022) (affirming denial of motion to disclose grand jury materials where the Government opposed release). A defendant's opposition to public disclosure is not dispositive. See In re Grand Jury Proceedings GJ-76-4 & GJ-75-3, 800 F.2d 1293, 1305 (4th Cir. 1986) (affirming district court's decision to disclose grand jury transcript and exhibits over defendant corporation's objection).\n\nDefendant Epstein has passed and therefore cannot assert a position.3 Defendant Maxwell has indicated that she expects “to craft a response and set out [her] position to the Court.” (Maxwell Dkt. 793).\n\n3. Why Disclosure Is Being Sought in the Particular Case\n\nThe third factor considers “why disclosure is being sought in the particular case.” In re Craig, 131 F.3d at 106. The Second Circuit in In re Craig held: “It is . . . entirely conceivable that in some situations historical or public interest alone could justify the release of grand jury information.” Id. As described above and in the underlying motions, there is undoubtedly a clearly expressed interest from the public in Jeffrey Epstein's and Ghislaine Maxwell's crimes. Beyond that, there is abundant public interest in the investigative work conducted by the Department of Justice and the Federal Bureau of Investigation into those crimes. See In re Am. Hist. Ass'n, 49 F.\n\n3 As noted below, the Government has not received any outreach from Epstein's surviving family concerning the instant motion.\n\n4\n\nDOJ-OGR-00000750",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 66 Filed 07/29/25 Page 5 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "nature of the instant request, it is also (like the Court) faced with a broad public interest in the underlying proceedings.\n\n2. Whether the Defendant to the Grand Jury Proceeding or the Government Opposes the Disclosure",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The second factor asks whether the defendant or the Government opposes public disclosure of grand jury materials. See In re Craig, 131 F.3d at 106; see also Lawyers' Committee for 9/11 Inquiry Inc. v. Garland, 43 F.4th 276, 285-86 (2d Cir. 2022) (affirming denial of motion to disclose grand jury materials where the Government opposed release). A defendant's opposition to public disclosure is not dispositive. See In re Grand Jury Proceedings GJ-76-4 & GJ-75-3, 800 F.2d 1293, 1305 (4th Cir. 1986) (affirming district court's decision to disclose grand jury transcript and exhibits over defendant corporation's objection).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Defendant Epstein has passed and therefore cannot assert a position.3 Defendant Maxwell has indicated that she expects “to craft a response and set out [her] position to the Court.” (Maxwell Dkt. 793).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. Why Disclosure Is Being Sought in the Particular Case",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The third factor considers “why disclosure is being sought in the particular case.” In re Craig, 131 F.3d at 106. The Second Circuit in In re Craig held: “It is . . . entirely conceivable that in some situations historical or public interest alone could justify the release of grand jury information.” Id. As described above and in the underlying motions, there is undoubtedly a clearly expressed interest from the public in Jeffrey Epstein's and Ghislaine Maxwell's crimes. Beyond that, there is abundant public interest in the investigative work conducted by the Department of Justice and the Federal Bureau of Investigation into those crimes. See In re Am. Hist. Ass'n, 49 F.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 As noted below, the Government has not received any outreach from Epstein's surviving family concerning the instant motion.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000750",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Department of Justice",
      "Federal Bureau of Investigation",
      "Lawyers' Committee for 9/11 Inquiry Inc."
    ],
    "locations": [],
    "dates": [
      "07/29/25"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 66",
      "DOJ-OGR-00000750"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein and Ghislaine Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is page 5 of 10."
}