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Case 322 ler QdSSOUAUIN DotdmleHP4 FPitdd B77 FOL PAGED St 20 take to protect herself, her family members, her friends and colleagues, and their children, from unrelenting and intrusive media coverage, threats, and irreparable reputational harm. Ever since Epstein’s arrest, Ms. Maxwell has been at the center of a crushing onslaught of press articles, television specials, and social media posts painting her in the most damning light possible and prejudging her guilt. The sheer volume of media reporting mentioning Ms. Maxwell is staggering. Since Epstein’s arrest, she has been mentioned in literally thousands of media publications, news reports, and other online content. The media attention also spawned a carnival-like atmosphere of speculation about her whereabouts. In November 2019, the British tabloid, The Sun, even offered a £10,000 bounty for information about Ms. Maxwell’s location. A headline reminiscent of a Wild West wanted poster read: “WANTED: The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal Ghislaine Maxwell.”!° And in the days leading up to her arrest, there was a deluge of media reports (all untrue) claiming that Ms. Maxwell was hiding out in an apartment in Paris to avoid questioning by the FBI.'! She has seen helicopters flying over her home and reporters hiding in the bushes. Indeed, since Ms. Maxwell’s arrest on July 2, 2020, her counsel has been flooded with hundreds of media inquiries and solicitations from members of the public. The “open season” declared on Ms. Maxwell after Epstein’s death has come with an even darker cost — she has been the target of alarming physical threats, even death threats, and has had to hire security guards to ensure her safety. The media feeding frenzy, which has only intensified in recent months, has also deeply affected her family and friends. Some of Ms. Maxwell’s closest friends who had nothing whatsoever to do with Epstein have lost their jobs or ° See https://www.the-sun.com/news/7401 8/the-sun-is-offering-a-10000-reward-for-information-on-jeffrey-epstein- pal-ghislaine-maxwell/. ! See, e.g., https:/Awww.dailymail.co.uk/news/ article-8444137/Jeffrey-Epsteins-fugitive-madam-Ghislaine- Maxwell-hiding-luxury-Paris.html. ls DOJ-OGR-00019894