DOJ-OGR-00000774.pdf

--- Page 1 --- **Document Header** * Case 1:19-cr-00490-RMB * Document 73 * Filed 08/05/25 * Page 4 of 4 **Case Information** * Honorable Richard M. Berman * Case No: 19 CR 490 (RMB) * Page 4 **Section 5: Defer or Deny Without Prejudice if Safeguards Cannot Be Assured** * If adequate safeguards cannot be implemented consistent with Rule 6(e), Pitch, and the CVRA, deny disclosure without prejudice. **Conclusion** * The survivors support transparency when it can be achieved without sacrificing their safety, privacy, or dignity. But transparency cannot come at the expense of the very people whom the justice system is sworn to protect—particularly amid contemporaneous events that magnify risk and trauma. Several victims have already died by suicide, drug overdose, or under tragic circumstances tied directly to the trauma caused by Jeffrey Epstein and Ghislaine Maxwell. These survivors have already endured profound violations of their rights and dignity, both during the years of Epstein's abuse and in the years following. To now compound their trauma by sidelining them from critical decisions—especially in this climate of heightened concern—is inconsistent with both the letter and the spirit of the CVRA. * The CVRA, Rule 6(e), and Eleventh Circuit authority all point toward narrow tailoring, maximal privacy protections, and meaningful victim participation before any grand jury material sees daylight. We respectfully ask the Court to adopt the safeguards outlined above. **Respectfully submitted,** * Bradley Edwards * Brittany Henderson * EDWARDS HENDERSON + 425 North Andrews Avenue, Suite 2 + Fort Lauderdale, Florida 33301 * Telephone: (954) 524-2820 * Email: brad@cvlf.com * brittany@cvlf.com * Paul G. Cassell + Utah Appellate Project + S.J. Quinney College of Law at the University of Utah + 383 S. University St. + Salt Lake City, UT 84112-0300 + Tel: 801-580-6462 + Email: pgcassell.law@gmail.com **Note** * (institutional address for identification purpose only; not to imply institutional endorsement)