My Letter to Judge Berman re: United States of America v. Jeffrey Epstein

The following letter has just been submitted, at 8:15pm EST, to Judge Richard M. Berman of the United States District Court for the Southern District of New York.

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December 5, 2025

VIA EMAIL

The Honorable Richard M. Berman

Re: United States of America v. Jeffrey Epstein, 1:19-cr-00490-RMB

Dear Judge Berman,

I am a journalist affiliated with Substack and other publications. I write in response to a November 25 letter submitted to Your Honor by attorneys Bradley Edwards and Brittany Henderson.

“The American people deserve to see everything… nothing is off limits… all files should come out.” These were the words of Mr. Edwards as he stood before the U.S. Capitol on September 3, 2025, calling for the release of what have colloquially become known as the “Epstein Files” — that is, records in the possession of government entities which may bear on matters related to Jeffrey Epstein, Ghislaine Maxwell, and their potential co-conspirators.

When he spoke from the podium that day, joined by sympathetic members of Congress and a large group of his own clients, Mr. Edwards conveyed a clear vision of what he was advocating for: full transparency and disclosure. Which is no doubt a goal that much of the public would find intuitively laudable. After all, who could oppose transparency and disclosure? Indeed, the political efforts undertaken by Mr. Edwards and his colleagues were ultimately successful. The legislation they championed, the Epstein Files Transparency Act, passed both chambers of Congress by a near-unanimous vote on November 18, 2025, and was signed into law the following day by President Trump.

And yet, a striking paradox has since emerged. When he’s not speaking in front of television cameras alongside politicians and media, but rather submitting letters to this Court, Mr. Edwards has adamantly opposed the comprehensive release of records believed to comprise the putative “Epstein Files.” In their letter to Your Honor, Mr. Edwards and Ms. Henderson inveigh that it is “absolutely unacceptable” (emphasis theirs) that certain records have already been published by the House Oversight Committee without the record custodians having first conferred with Mr. Edwards and Ms. Henderson, to allow them to impose their own preferred redactions — or, in other words, to ensure that certain records are concealed based on the private opinion formed by Mr. Edwards and Ms. Henderson as to which records ought to be shielded from public inspection. In so doing, Mr. Edwards and Ms. Henderson have strangely demanded that a critical state function — determining which records qualify for disclosure in accordance with the Epstein Files Transparency Act — be outsourced to them, as private parties. They curiously demand in their letter that Your Honor issue an “order” on their behalf, requiring that the Department of Justice “consult” with Mr. Edwards and Ms. Henderson as additional records are prepared for disclosure.

Your Honor is respectfully encouraged to carefully consider the implications of this audacious demand. For why should these two private attorneys — whose self-interested incentives in this matter, financial and otherwise, are beyond dispute — be effectively granted veto power to stymie the release of certain records which Congress has overwhelmingly decided are in the public interest to disclose? Your Honor should please bear in mind that Mr. Edwards and Ms. Henderson have recently filed lawsuits against large financial institutions¹ from which they stand to reap enormous personal benefit — the success of which could plausibly be imperiled by the disclosure of records outside counsel’s control. Similar litigation that Mr. Edwards, Ms. Henderson and colleagues previously initiated against J.P. Morgan culminated in 30% of the resulting settlement funds, $290 million, being earmarked for “attorneys’ fees.”² Surely, no attorneys’ financial interests, nor any other extraneous interests, should be permitted to dictate the parameters of a records-disclosure process mandated by Congress — even if those attorneys might cast their implorations for records-concealment in the seemingly selfless language of “protecting victims.”

In their letter to Your Honor demanding the ability to micro-manage the records-disclosure process, Mr. Edwards and Ms. Henderson stress that their clients who claim to have been victimized as “adult women” by Mr. Epstein and Ms. Maxwell are owed particular deference by government officials, and consequently, an unknown expanse of records must be withheld on their behalf. But one could just as credibly argue that deciphering the proportion of self-identified victims who, by their own admission, were adults at the time of their claimed victimization is squarely in the public interest — given understandable public consternation that rampant “pedophilia” and “child sex-trafficking” may have gone unpunished. Such consternation is undoubtedly a major factor in what impelled Congress to near-unanimously pass the Epstein Files Transparency Act. As such, elucidating the spectrum of purported adult victims versus purported minor victims would serve to enhance public understanding of matters surrounding Mr. Epstein and Ms. Maxwell, which have generated such controversy and grievance. Maximum disclosure is precisely the correct antidote, even if it could possibly jeopardize litigation brought by Mr. Edwards and Ms. Henderson, who in their Bank of America action are representing a Jane Doe who claims to have been “indoctrinated” into a sex-trafficking “cult” by Mr. Epstein, during a period in which Jane Doe was admittedly at all times an adult.

It should also be noted that virtually none of the purported adult victims of Mr. Epstein whose privacy interests Mr. Edwards and Ms. Henderson contend supersede the public’s interest in maximum disclosure have ever been adjudicated as victims in any properly interrogative context. Notwithstanding inflammatory assertions from Mr. Edwards and Ms. Henderson in their letter to Your Honor that Mr. Epstein somehow managed to “enslave” these adult victims in broad daylight, for well over a decade, without any competent law enforcement authorities ever noticing this sensational crime in progress.

While it is true that “victims” who were admittedly adults at the time of their claimed victimization were eligible for remuneration under the court-approved terms of settlement programs stemming from prior litigation brought by Mr. Edwards and colleagues against such entities as Mr. Epstein’s estate, J.P. Morgan, and Deutsche Bank, these programs were expressly structured as “non-adversarial” and “confidential” mechanisms by which to distribute payments holistically and expeditiously to a large class of claimants.³ Records submitted to these programs by claimants were subsequently “destroyed,” thus preventing any ability by the public to evaluate the veracity of claimants’ self-descriptions of victimhood.⁴ With such a fatal dearth of evidence available to substantiate their anonymous claims, it beggars belief that claimants should now be permitted to arrogate authority through counsel to hinder the transmission of records authorized for public disclosure by Congress.

Doubly worrisome is that the Department of Justice, in its November 26 letter to Judge Engelmayer⁵ has stated that “the Government intends to redact identifying information for anyone who identifies themself as a victim in connection with this process.” Surely, mere “self-identification” could not be sufficient grounds for a government agency to designate some individual a “victim,” absent any ascertainment of corroborating evidence, and absent any semblance of a verifiable process to determine if such claims have merit. For the specious standard of mere “self-identification” to be cited as grounds to continue concealing records which Congress has otherwise required the Executive Branch to disclose would be a flummoxing affront to good sense.

Your Honor would be well-advised to consider the recommendations of Sir Richard Henriques, the distinguished barrister in the United Kingdom who undertook a rigorous examination of efforts by British authorities to investigate decades-old claims of sexual abuse. The investigation proved to be a fiasco, producing a torrent of scandalous accusations against prominent individuals which were later determined to have been entirely fictitious. In his final report, Mr. Henriques wrote:

All ‘complainants’ are not ‘victims’. Some complaints are false and thus those ‘complainants’ are not ‘victims’. Throughout the judicial process the word ‘complainant’ is deployed up to the moment of conviction where after a ‘complainant’ is properly referred to as a ‘victim’. Since the entire judicial process, up to that point, is engaged in determining whether or not a ‘complainant’ is indeed a ‘victim’, such an approach cannot be questioned. No Crown Court judge will permit a ‘complainant’ to be referred to as a ‘victim’ prior to conviction. Since the investigative process is similarly engaged in ascertaining facts which will, if proven, establish guilt, the use of the word ‘victim’ at the commencement of an investigation is simply inaccurate and should cease.⁶

Likewise, there has been no bonafide process by which anywhere close to requisite evidence has been produced that could satisfactorily establish whether the adult “victims” represented by Mr. Edwards and Ms. Henderson are in fact verifiable “victims.” Ordinary private citizens are of course free to ascribe the label of “victim” to whomever they like, based on whatever information they deem sufficient to establish that ascription. But agents of the state, especially those charged with overseeing the disclosure of records that carry significant public import — certainly including records believed to comprise the “Epstein Files” — should surely be obliged to employ far more exacting and scrupulous standards than must ordinary private citizens when they apply the label of “victim.” Withholding certain records based on claims of purported victimhood which have never been tested, have been shrouded in deliberate secrecy, and could well be proven false in a properly inquisitional format, surely must violate basic notions of public responsibility and fidelity to factual rigor. Improper use of the word “victim” when no victimhood has ever been substantively established is already dubious enough. But using unproven and potentially unfounded designations of “victimhood” as grounds to withhold public records — which have been expressly authorized by Congress for release — is another level of malpractice.

The legislative intent of the Epstein Files Transparency Act is clear. Representative Thomas Massie, a principal drafter and co-sponsor, has stated bluntly that the law was intended to compel “the complete release of the government’s files related to Jeffrey Epstein.”⁷ Hence, any attempt to curtail the production of a “complete” public record would plainly contradict the law’s manifestly cognizable intent. While certain “permitted withholdings” are contemplated in the legislative text — including around “personally identifiable information of victims” and “national defense” — these withholdings are not obligatory.⁸ Rather, the text merely states that the Attorney General “may” (as opposed to “shall”) exercise discretion to withhold certain records, in the event that she may deem such records to meet “narrowly tailored” criteria for “segregable” exceptions.

Sweeping demands for continued records concealment, as expounded by Mr. Edwards and Ms. Henderson, plainly run afoul of the spirit of the law, and the purposes for which it was introduced, lobbied for, and enacted. Its other principal drafter and co-sponsor, Representative Ro Khanna, has stated: “We need a full release of the Epstein files.”⁹ Emphasis mine on “full.” This exhortation from Rep. Khanna is simply not compatible with the overly expansive criteria set forth by Mr. Edwards and Ms. Henderson to govern the universe of records which, in their opinion, must remain concealed in perpetuity. They implore Your Honor in their November 25 letter (emphasis theirs) that “transparency CANNOT come at the expense of the privacy, safety, and protection of sexual abuse and sex trafficking victims.” They then claim to have compiled a “confidential list” of “over 300 victims” whom they insist the government must use as a guidepost to redact or withhold certain records, if those records can be claimed to contain unduly “identifying information” related to these anonymous purported victims. One can only imagine the vast array of records that could potentially be concealed if the government were to oblige Mr. Edwards and Ms. Henderson’s demand. For instance, if a self-identified victim hypothetically made certain allegations of wrongdoing that were investigated by the government, and found to lack merit, would some record that was produced to memorialize this finding now have to be concealed indefinitely, simply because the record can be claimed to intrude on the “identifying information” of the self-identified victim who made the meritless allegation?

Even among the small number of self-identified victims who did take part in a properly adjudicative process — namely, the four witnesses whom the government called to testify in the criminal trial of Ms. Maxwell in 2021 — ambiguities abound. In a December 2, 2025 letter to Your Honor by Sigrid S. McCawley, counsel for Annie Farmer, Ms. McCawley repeats the oft-heard injunction that “redactions” be imposed on any forthcoming records, insofar as such redactions are “necessary to protect victims’ names, likenesses, and identifying information.” However, Ms. Farmer has publicly identified herself as a “victim” of Mr. Epstein and Ms. Maxwell for many years now. She appears regularly on television and podcasts, speaks at political rallies, lobbies for legislative action, confers with elected officials, and has openly described the circumstances of her purported victimization in great detail. Moreover, Ms. Farmer voluntarily chose to testify at the 2021 Maxwell trial under her full name, even as Judge Nathan offered the option for government witnesses to testify under pseudonyms. Given all the information Ms. Farmer has already chosen to make available for public consumption, what grounds could there possibly be to redact or withhold any records which may be said to intersect with her “name, likeness, or identifying information”? Is the name “Annie Farmer” going to be redacted in forthcoming record releases? Based on the demands in a publicly-available letter in which Ms. Farmer once again freely names herself?

As the U.S. Supreme Court held in Cox Broadcasting Corp. v. Cohn (1975), “the interests of privacy fade when the information involved already appears on public record,” even with respect to “publication of the name of a rape victim.” Such a dictum should plainly encompass any present claims by Ms. Farmer that her privacy interests must preclude the disclosure of certain records, as she has already revealed her name long ago, and has already testified in open court as to the circumstances of her purported victimization. Further, the bar for redacting any records which may pertain to Ms. Farmer must be drastically lower than the bar enumerated by the Supreme Court in its aforementioned decision, given that Ms. Farmer has never claimed to be a “rape victim.” Indeed, she attested under examination at trial that the “sexual abuse” she allegedly underwent, by her own telling, included physical acts such as “hand-holding.” Whatever the particulars of Ms. Farmer’s allegations, Judge Nathan saw fit to instruct jurors that “the alleged physical contact [Ms. Farmer] says occurred with Mr. Epstein and Ms. Maxwell” did not constitute “illegal sexual activity” for the purposes of convicting Ms. Maxwell.¹⁰ Only through a painstaking discovery process — which unearthed records that prosecutors and Ms. Farmer had petitioned to keep concealed — did the evidence emerge which then served as the basis for Judge Nathan’s instruction.

Excessive deference to the demands of purported victims to thwart disclosure of certain records would fly in the face of rulings already rendered in this District. Judge Rakoff has reasoned that such demands made on behalf of “victims” can be superseded by the public’s interest in disclosure — and overwrought “concerns” raised by their counsel can be dismissed as failing to justify demands for concealment. In 2024, Ms. McCawley, representing Jane Doe, vigorously opposed a motion by the New York Times to unseal certain judicial documents, arguing that her anonymous client’s “privacy interests strongly outweigh… the presumption of public access” to the relevant documents.¹¹ Ms. McCawley claimed that by unsealing a deposition transcript, her unnamed client would “be forced to relive… traumatic moments from her deposition publicly.” Merely redacting her client’s name would not be enough, however, because Ms. McCawley argued “the mere redaction of her name would not protect her from re-traumatization.” Ms. McCawley further cited the “fears” her client allegedly harbored of being “retaliated” against by unknown malefactors in the event of the deposition’s public disclosure.

Judge Rakoff rejected these arguments, and ordered the unsealing of deposition transcripts which contained precisely the information Ms. McCawley warned could dangerously “identify” her client. The transcripts were published on October 4, 2024.¹² In the more than a year since, no evidentiary record is known to have emerged demonstrating that the “fears” Ms. McCawley expressed on her client’s behalf had any well-founded basis. Perhaps the Court could inquire with Ms. McCawley for an update, in order to assess the after-the-fact credibility of these professed “fears.”

Indeed, this is but one recent example of anti-disclosure arguments made by counsel for purported victims having been shown to be, at the very least, overblown — and not credibly rooted in the actual “risk” posed by the appropriate disclosure of records. Mr. Edwards and Ms. Henderson likewise now claim to Your Honor that their unnamed clients are “overwhelmed by constant fear of exposure, reprisal, and re-victimization.” Such claims are so nebulous and non-specific as to be almost intrinsically precluded from any legible evaluation. First, criteria for inclusion in this ever-expanding assemblage of “victims” who are purportedly fearful of “re-victimization” have been kept resolutely hidden. The only discernible criterion is self-identification — the same unworkable standard the Department of Justice has worryingly stated will now guide its own record-redaction process. Even if certain individuals in the putative “victim” category do purport to feel certain “fears,” no legitimate grounds have been articulated for why these “fears” should justify the sweeping concealment of records. Untested, uncorroborated, anonymously-communicated “fears” cannot possibly override the public’s entitlement to records that Congress has near-unanimously approved for disclosure. Moreover, the Epstein Files Transparency Act expressly provides that “no record shall be withheld, delayed, or redacted” on the basis of potential fears involving “embarrassment” or “reputational harm.” Hence, the alleged basis for any claimed “fears” must be interrogated, as the mere expression of purported “fears” cannot justify the capricious concealment of records, lest the law’s sub-section on “prohibited grounds for withholding” be violated.

Furthermore, it must be emphasized that every conceivable self-identified victim would have to be a full-fledged adult by December 2025, with the very youngest among them almost certainly in their 30s. Hence, there is no question of any present-day minors potentially having their privacy interests infringed. Courts — and for that matter, the media — should decline to rely on speculative assertions that transparency and disclosure could vaguely imperil the “safety” of purported victims who are presently adults. Over-expansive accommodation to the demands of these self-identified victims stands as a stark impediment to the stated purpose of the Epstein Files Transparency Act, whose drafters have repeatedly called for “full” and “complete” production of all pertinent records. Your Honor is respectfully requested to be mindful of how an over-broad conception of “victims” could be invoked to stifle this clearly-articulated legislative purpose.

In a July 6, 2025 memo, the Department of Justice and Federal Bureau of Investigation stated that “over one thousand victims” were “harmed” by Mr. Epstein — though the manner in which this “harm” was purportedly inflicted is not specified, nor is any clarity given as to how this conspicuously imprecise figure of “over one thousand” was calculated. Additionally, the “harms” purportedly inflicted on adults is not distinguished from the harms purportedly inflicted on minors. As mentioned earlier, a significant percentage of self-identified victims who have recently made public statements, or engaged in public political advocacy, were self-admittedly adults at the time of their claimed victimization — notwithstanding the common misperception that any purported “victim” of Mr. Epstein must ipso facto be a victim of “pedophilia” or “child sex-trafficking.”

The DOJ and FBI memo further claims government investigators recovered an unspecified quantity of “images of illegal child sex abuse material and other pornography” from Mr. Epstein’s properties. But no explanation is given for why “illegal child sex abuse material” has been grouped together with “pornography,” seeing as the DOJ now advises the proper terminology for such material is “child sexual abuse material,” to replace the antiquated term “child pornography.”¹³ Presumably, according to DOJ guidelines, any illicit sexual material featuring persons under the age of 18 would no longer be referred to as “pornography.” Hence, whatever “pornography” the government claims to have recovered from Mr. Epstein’s properties could plausibly depict adults, thus making the material facially legal, unless there are other extenuating facts or circumstances which the government has so far declined to elucidate. This confusion merely underscores the need for genuinely comprehensive disclosure of any and all pertinent records, even if disclosure can be alleged to potentially impinge on the “identifying information” of certain purported victims.

Indeed, the July 6 memo states that the DOJ and FBI concluded “no further disclosure” of any records “would be appropriate or warranted,” in part on the ground that “sensitive information relating to these victims is intertwined throughout the materials.” This suggests an inordinately large cross-section of records could be exempted from the disclosure mandated by the Epstein Files Transparency Act, if the materials at issue are so pervasively “intertwined” with information that may bear on the identities of purported victims. Surely there exists a strong civic imperative to create as complete a public record as possible, given widespread popular misgivings around the matter of Mr. Epstein and Ms. Maxwell. Employing over-broad criteria to conceal a large volume of materials for the ostensible purpose of protecting self-identified “victims” would surely necessitate that the public record remains woefully incomplete — and thus popular misgivings would only persist, sparking ever more mistrust and suspicion.

Mr. Edwards and Ms. Henderson maintain that disclosure of records has already “caused significant emotional distress” for their anonymous clients. Whether true or not — and scant evidence has been put forward to substantiate these claims of “emotional distress” — it is simply untenable that such conspicuously vague claims could be allowed to supersede the resounding public interest in producing the most comprehensive possible record of all available “Epstein Files.” The passage of the Epstein Files Transparency Act confirms the exceptional circumstances attendant to this matter. It is atypical, to say the least, for Congress to direct that investigatory files underlying what the government has otherwise deemed a “closed” investigation must be released en masse for public inspection. However, historic levels of popular interest in this matter have plainly given rise to the enactment of an exceptional law. Surely the Court cannot countenance arguments by Mr. Edwards and Ms. Henderson that the public’s overwhelming interest in comprehensive disclosure should be subordinated to the “distress” these lawyers vaguely claim could be theoretically experienced by their anonymous clients.

With respect to what affordances are allegedly due the purported victims, it should be noted that those claiming to have been victimized by Mr. Epstein and Ms. Maxwell have already received extraordinary and even unprecedented levels of compensation. Nearly $500 million has been made available to self-identified victims pursuant to the terms of just three settlement funds — the Epstein Victims’ Compensation Program, drawn from Mr. Epstein’s estate; the J.P. Morgan class-action settlement; and the Deutsche Bank class-action settlement. Mr. Edwards and Ms. Henderson were intimately involved in effectuating all three, and were themselves amply compensated for their efforts. As previously mentioned, Mr. Edwards and Ms. Henderson have now targeted at least two additional financial institutions, by way of their recently filed actions against Bank of America and the Bank of New York Mellon. Many more millions of dollars have also been obtained from individualized settlements, both publicly known and, upon information and belief, secret.

One recipient of this compensation who has publicly identified herself as an adult “grooming” victim, Lisa Phillips, recently called attention to yet another source of compensation to which self-identified victims like herself are entitled. Under the terms of a 2023 settlement obtained by the government of the U.S. Virgin Islands against J.P. Morgan, for its alleged role in facilitating the conduct of Mr. Epstein, a separate fund of $10 million has been established to offer state-of-the-art “mental health” services to purported victims, including to self-identified adult victims such as Ms. Phillips. Services including “Equine-Assisted Psychotherapy” and “Trauma-Informed Yoga” will remain available, all expenses paid, to self-identified victims through at least 2028.¹⁴ Many self-identified victims are currently employed by organizations celebrating their courage and accomplishments.¹⁵ According to Mr. Edwards, the government has even paid for the travel expenses of self-identified victims.¹⁶ Put simply, there has been no shortage of compensatory accommodations — both public and private — made for the self-identified victims of Mr. Epstein and Ms. Maxwell. The notion that their interests should still nonetheless trump the public’s interest in accessing the full scope of these records frankly defies reason.

There are also self-identified victims such as Sarah Ransome — once represented by Mr. Edwards and Ms. McCawley¹⁷ — who eventually admitted to outright fabricating (emphasis mine) the existence of sex tapes featuring certain prominent individuals which she claimed to have in her possession. Another self-identified victim, Virginia Roberts Giuffre, acknowledged in a statement that she “may have made a mistake” in identifying a certain individual whom she had repeatedly accused of committing graphic sex crimes against her. It would thus be irrational for any record held by a government entity to be concealed on the ground that it may interweave the “identifying information” of either Ms. Ransome and Ms. Roberts Giuffre. Both long ago chose to voluntarily make their identities public, took part in extensive litigation in which they were publicly named, made innumerable high-profile media appearances, authored their own published books, inter alia. Further, Ms. Roberts Giuffre has been reported deceased as of April 25, 2025, which should presumably extinguish whatever “privacy interests” might be cited on her behalf to conceal any records that could contain her “identifying information.”

Excessive compliance with “victim protection” strictures has already led to absurd and avoidable situations such as when the name of Ms. Roberts Giuffre was redacted in the transcript of the July 24-25, 2025 proffer interview conducted with Ms. Maxwell by the Deputy Attorney General, Todd Blanche. Readers of the transcript who had even the barest familiarity with the relevant factual details would have immediately surmised that Ms. Roberts Giuffre was the individual referenced in various exchanges between Mr. Blanche and Ms. Maxwell, thus rendering the redactions superfluous. Records released by the House Oversight Committee on November 12, 2025 likewise initially redacted the name of Ms. Roberts Giuffre, even though she could again be plainly surmised as the individual referenced in the document.¹⁸ This was confirmed when other members of the Committee subsequently released an unredacted version of the document, making visible the name of Ms. Roberts Giuffre. Nonsensical outcomes such as these are entirely avoidable, if record custodians would simply adhere to the simple directive propounded by the sponsors of the Epstein Files Transparency Act, Rep. Massie and Rep. Khanna, who have been adamant in their call for a “full” and “complete” release of all relevant files in the government’s possession. Diluting this imperative with histrionic appeals to the ill-defined “safety” concerns of purported victims will manifestly impair the government’s ability to fulfill its prescribed duty.

Indeed, a political judgment has been made that records in the government’s possession which would ordinarily never be released, given that certain of the records could wrongly impugn innocent individuals as perpetrators of heinous child sex crimes, should nonetheless be released in this one anomalous and exceptional circumstance — due to historic public interest in matters surrounding Mr. Epstein and Ms. Maxwell. Any defamatory harms which may consequently be inflicted on innocent individuals have thus been made subordinate to a paramount public interest: assembling the completest possible record of “Epstein Files.” Jeopardizing this goal out of misplaced deference to self-identified victims would be a travesty on multiple fronts. First, it would ensure that public suspicions and misgivings are not quelled, but intensified, contrary to the clear intent of the Epstein Files Transparency Act. And it would also consecrate the practice of fallaciously ascribing “victimhood” status to individuals whose claims were never meaningfully adjudicated.

For these and many other reasons, Your Honor is respectfully requested to recognize the intent of a near-unanimous Congress, as representatives of the wider public, for full and complete disclosure of all records understood to fall under the banner of “Epstein Files” — and in so doing, reject onerous demands by self-identified victims and their counsel to stifle, impede, restrict, curtail, or otherwise prevent this necessary disclosure, on the misguided premise that the interests of anonymized and already well-compensated “victims” should override the rest of the Nation’s interests in respect to a matter that has generated such enormous public controversy. Indeed, Your Honor is respectfully requested to trust in the wisdom of the people, as expressed by their elected representatives, to make sound judgments based on a thorough examination of all relevant records — come what may.

Sincerely,

Michael Tracey

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1. Jane Doe v. Bank of America, N.A., 1:25-cv-08520-JSR, filed October 15, 2025

2. Doe 1 v. JP Morgan Chase & Co., 1:22-cv-10019-JSR, Document 278, filed November 7, 2023

3. February 4, 2020 testimony of Epstein Victims’ Compensation Program administrator Jordana Feldman in the Superior Court of the Virgin Islands, St-19-PB-0080

4. May 29, 2020 court-approved protocol for Epstein Victims’ Compensation Program, 1:20-cr-00330-AJN

5. November 26, 2025 letter by Pamela J. Bondi, Todd Blanche, and Jay Clayton to Judge Engelmayer, United States v. Ghislaine Maxwell, 1:20-cr-00330-PAE, Document 813

6. The Independent Review of the Metropolitan Police Service’s handling of non-recent sexual offence investigations alleged against persons of public prominence, Sir Richard Henriques, October 31, 2016

7. July 15, 2025 press release, Reps. Massie, Khanna Seek House Vote on Public Release of Jeffrey Epstein Files, available at https://massie.house.gov/

8. H.R.4405 — Epstein Files Transparency Act, introduced July 15, 2025

9. November 18, 2025 press release, Rep. Khanna’s Bill to Release the Epstein Files Passes the House, available at https://khanna.house.gov

10. December 10, 2021 limiting instruction to jurors by Judge Nathan in United States vs. Ghislaine Maxwell, 1:20-cr-00330-AJN

11. Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., 1:22-cv-10904-JSR, Document 353, filed March 12, 2024

12. Document 369, filed March 4, 2024, in Government of the United States Virgin Islands v. JPMorgan

13. Department of Justice guidance on “Child Sexual Abuse Material,” dated June 2023

14. “USVI Mental Health Fund – Overview & Application Instructions,” last updated August 4, 2025

15. “Meet The Survivors, Inc. Team,” available at https://www.thesurvivorsinc.org/team

16. “Relentless Pursuit” (2020) by Bradley Edwards, page 19

17. Jane Doe 43 v. Epstein, 1:17-cv-00616, filed January 26, 2017

18. Memo by Oversight Committee Republican Staff, published November 16, 2025