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Document Case 1:20-cr-00330-AJN Document 272 Filed 08/07/20 Page 3 of 31

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The Honorable Alison J. Nathan July 21, 2020 Page 3 Recent Prejudicial Public Statements by the Government, its Agents and Counsel to Prospective Witnesses Recent public statements by the Government, its agents and counsel for prospective witnesses have included presumptively prejudicial information. On July 2, 2020 Ms. Maxwell was arrested without notice to her lawyers who had been in active communication with the Government for one year. Because plain vanilla surrenders lack the fanfare and attendant media coverage afforded to secret, armed, raids at dawn, the Government chose to invade Ms. Maxwell's New Hampshire residence, arrest her, and stage a media presentation that included numerous statements that prejudice Ms. Maxwell's right to a fair trial. Immediately following Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press conference in which she commented on Ms. Maxwell's credibility and her incorrect opinions concerning "guilt or innocence or as to the merits of the case or the evidence in the case" in violation of Local Rule 23.1(d)(1), (4) and (7): Per the New York Law Journal: 'Maxwell lied because the truth, as alleged, was almost unspeakable,' Strauss said at a press conference announcing the charges. 'Maxwell enticed minor girls, got them to trust her and then delivered them into the trap that that she and Epstein had set for them. She pretended to be a woman they could trust, all the while she was setting them up to be sexually abused by Epstein and, in some cases, by Maxwell herself.'1 As reported in the Washington Post, Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and others in deposition because the truth 'was almost unspeakable.' Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell case 'the prequel' to the charges they lodged against Epstein.... Maxwell played a critical role in helping Epstein to identify, befriend, and groom minor victims for abuse' ... 'In some cases Maxwell participated in the abuse itself.'2 1 https://www.law.com/newyorklawjournal/2020/07/02/ghislaine-maxwell-arrested-in-connection-with-jeffrey-epstein-sex-trafficking-ring/?slreturn=20200614124921 2 https://www.washingtonpost.com/national-security/ghislaine-maxwell-arrested-jeffrey-epstein/2020/07/02/20c74502-bc69-11ea-8cf5-9c1b8d7f84c6_story.html App.033 DOJ-OGR-00019492