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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 19 of 26 information, she could articulate the prejudicial loss of these records and witnesses with more specificity. VI. Prejudice Resulting from Prejudicial Media Reporting and Inappropriate Pre-Trial Publicity. Beginning in 2005 and escalating in 2011 through the present, Ms. Maxwell has been a potential target of a group of personal injury lawyers who made millions of dollars suing Jeffrey Epstein or extorting those associated with him. The playbook was relatively simple: File incendiary pleadings in court to avoid defamation claims; provide the pleadings and background information to various media organizations; obtain alleged victim’s names and police reports from law enforcement; share information with potential claimants who hire the lawyers after reading or hearing the reports; file a lawsuit against Mr. Epstein; get money from Mr. Epstein or associates to settle; repeat. Once Mr. Epstein had settled all of these claims against himself and the other individuals alleged to have been involved, a new play was necessary - try to invalidate the NPA; and at the same time drum up litigation against Maxwell with the expectation that either Mr. Epstein would settle any new litigation to avoid being dragged into yet another case that would further tarnish the reputation he was trying to rebuild or result in money directly from Ms. Maxwell. From 2011 to 2019, Ms. Maxwell was the subject of millions of media stories, posts, blogs, podcasts, and comments that simply republished the same allegations that she correctly identified as “obvious lies” in 2015. Once New York passed L. 2019, ch. 11, known as the Child Victims Act, the door was open to claimants who wanted to take advantage of Mr. Epstein’s vulnerability to file new lawsuits on stale allegations. At that point it easy to make copycat 14 DOJ-OGR-00002522