BREAKING: JUDGE SULLIVAN ORDERS DOJ TO HAND OVER FBI NOTES IN EPSTEIN FILES FIGHT — SEPT. 24 DEADLINE TIGHTENS PRESSURE ON TODD BLANCHE
A federal judge has ordered the Justice Department to submit disputed handwritten FBI interview notes for private judicial review, begin review and production of foreign-language Epstein materials, and answer Katie Phang’s lawsuit on a fixed schedule. The notes concern an unverified allegation involving President Donald Trump; Trump has denied wrongdoing and has not been charged in connection with that allegation.
WASHINGTON — The newest order in Katie Phang’s lawsuit over the Epstein files does not release a bombshell to the public. It does something more procedural — and potentially more consequential: it puts disputed evidence directly in front of a federal judge.
U.S. District Judge Emmet G. Sullivan has ordered the Justice Department to submit redacted and unredacted versions of handwritten FBI notes underlying four interview reports for in-camera review by September 24, according to the latest docket developments in Phang v. Blanche. The same deadline also requires the government to notify the court that it has begun review and production of foreign-language materials covered by the Epstein Files Transparency Act.
The distinction matters. Sullivan has not ruled that the handwritten notes must immediately be published, and he has made no finding that the allegation described in the underlying interview reports is true. What he has done is remove the dispute from a war of competing descriptions and place the records themselves before the court.
Sullivan Puts the Handwritten FBI Notes in Front of the Court
The fight over the handwritten notes has been building since June, when Sullivan granted Phang a preliminary injunction in her suit against Todd Blanche in his official capacity as Acting Attorney General. Phang, an attorney and independent journalist, argues that the Justice Department failed to comply fully with the Epstein Files Transparency Act, the disclosure law President Trump signed in November 2025.
Among the categories she challenged were the underlying notes used to prepare four FBI FD-302 interview reports. An FD-302 is the typed report agents use to memorialize an interview; the handwritten notes are a separate set of records created during the questioning itself.
In his June opinion, Sullivan rejected the idea that the underlying notes could simply be treated as duplicates of the typed reports. The court emphasized that DOJ’s own review protocol did not create a blanket exception for documents merely because they were substantially similar to something already released.
The latest order now requires those notes to be placed before Sullivan in both redacted and unredacted form. That means the next judgment about what may properly remain hidden will be made after the judge sees the material himself, rather than relying only on the government’s description of it.
The Most Explosive Part of the Case Is Still an Allegation — Not a Finding
The four interview reports at the center of the handwritten-notes dispute concern statements from a woman who alleged that Jeffrey Epstein introduced her to Donald Trump when she was about 13 and that Trump assaulted her. The allegation is serious, but the legal posture is equally important: it remains unverified, it has not produced criminal charges against Trump, and Sullivan’s orders do not adjudicate whether it is true.
The Guardian reported earlier this year that FBI memoranda contained explicit but unsubstantiated allegations from the same woman and noted inconsistencies and a lack of corroboration. Axios likewise reported that Trump has denied wrongdoing in connection with Epstein-related allegations and has not been charged with a crime arising from them.
That is why the in-camera process matters. The court can review the original records while protecting identifying information and other material that may lawfully remain redacted. Only after that review could Sullivan decide whether further disclosure is required under the statute.
So the real headline is not that the public is about to receive dozens of pages on September 24. The headline is that the government must finally put the disputed pages in the judge’s hands on September 24.
DOJ Missed Its Answer Deadline — and Lost the Chance to File a Late Dismissal Motion
A second order issued September 16 addresses a more basic procedural problem: the government missed the deadline to respond to Phang’s complaint.
According to the court’s memorandum and order, Blanche’s deadline to respond was June 26. The government did not file a response and did not seek an extension before or after the deadline. Sullivan is allowing the government to file an answer late, but he is not allowing it to use the delay to file a late motion to dismiss instead.
The answer is now due September 24. Sullivan also set deadlines for the administrative record — the materials that show how the agency made the decisions being challenged in the case. A certified list of that record is due October 1, and the record itself is due to Phang’s legal team by October 15.
Those dates move the lawsuit beyond a narrow fight over a few redactions. The administrative record can become central in an Administrative Procedure Act case because it shows what information the agency considered, what standards it applied, and how it reached the decisions now under review.
Foreign-Language Epstein Materials Are Back Under a Court Deadline
The foreign-language records are the other major piece of the new order. Sullivan’s June preliminary injunction had already directed the department to initiate review and production of foreign-language material that may fall within the Epstein Files Transparency Act.
At an August status hearing, the timing and status of that work became a point of dispute. Phang has argued publicly that the government had not begun the process despite the earlier order. DOJ has disputed broader claims of noncompliance and has appealed the preliminary injunction.
The September order now requires notice by September 24 that review and production have been initiated. It does not say every foreign-language document must be translated and publicly posted by that date. It does, however, force the government to tell the court that the process has started.
That distinction is less dramatic than the commentary surrounding the case, but legally it is cleaner: the court is converting an open-ended compliance dispute into a dated obligation that can be measured against the docket.
A Parallel Pressure Track Is Building in Congress
The courtroom fight is unfolding at the same time Congress is pursuing its own Epstein-related oversight. On September 16, the House Oversight Committee voted 41-0 to recommend contempt proceedings against financier Leon Black after a subpoena dispute tied to the committee’s investigation of Epstein’s network.
Black has denied wrongdoing and has said he had no knowledge of Epstein’s criminal conduct. The congressional dispute is separate from Phang’s lawsuit, but the timing reinforces a broader point: the Epstein records story is no longer moving through a single channel.
There is litigation over statutory disclosure, congressional oversight over witnesses and records, a DOJ document library that continues to be scrutinized, and an appeal pending in the D.C. Circuit over Sullivan’s preliminary injunction. Each track has different legal rules, and none by itself proves allegations contained in the records.
That last point is essential. Disclosure litigation determines what records the government must release or justify withholding. It does not convert every statement inside an investigative file into a judicially established fact.
Why the Administrative Record Could Become the Bigger Fight
The handwritten notes will attract the most attention because they touch an allegation involving a sitting president. But the administrative record may ultimately reveal more about the mechanics of the Justice Department’s disclosure process.
Phang’s complaint is brought under the Administrative Procedure Act. In that kind of case, the court reviews the agency action and the basis for it. The record can show which documents and rules officials relied upon when deciding what to release, what to redact, and what to withhold.
Sullivan’s June opinion already criticized the government’s briefing in unusually direct legal terms. He wrote that, by failing to respond substantively to several of Phang’s merits arguments at the preliminary-injunction stage, the Attorney General had conceded those arguments for purposes of that motion. The Justice Department has appealed that ruling and continues to contest Phang’s claims.
The new October deadlines therefore matter beyond paperwork. They create a path for the plaintiff and the court to examine the decision-making process itself, not only the final blacked-out pages that appeared in the public database.
What Happens Next: September 24 Is a Checkpoint, Not the Finish Line
September 24 now carries several deadlines at once. DOJ must file its answer to the complaint. It must submit the disputed handwritten FBI interview notes for Sullivan’s private review. It must provide materials supporting certain victim-name redactions for the same kind of review. And it must notify the court that review and production of foreign-language material has begun.
Then come October 1 and October 15 for the administrative record. Meanwhile, Blanche’s appeal of the June preliminary injunction remains pending in the D.C. Circuit.
What the public should not expect is an automatic document dump on September 24. In-camera review means the judge sees the material first. Any public release, further redaction order, or additional compliance ruling would require another step.
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That is where the case now sits: not at a verdict on the allegations inside the files, and not yet at public release of the handwritten notes, but at a point where the Justice Department has a series of dates it must meet and a federal judge is preparing to inspect the disputed evidence himself.
The next major development may therefore be less theatrical than the headlines — a docket entry, a sealed submission, a notice of compliance. But in a case built around what the government must disclose, those procedural moves are the story.
