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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 20 of 26 claims about Ms. Maxwell because of the passage of time.® A review of the media coverage of the Epstein story reflects an unwarranted transformation of Ms. Maxwell from Epstein friend to Epstein conspirator. This re-casting by the media has no basis in fact but is the cumulative effect of publishing or republishing untrue assertations about Ms. Maxwell. Had the government brought any charges against Ms. Maxwell in 1996-2011 it (a) would have not prevailed and (b) none of the accusers would have been able to conform their “memories” to the often republished “obvious lies.” VII. The Reckless, Tactical, or Bad Faith Delay. There is no legitimate justification for the extraordinary delay associated with this prosecution. Tactical, reckless, and bad faith motives can reasonably be inferred from the way the government has ignored evidence, delayed any prosecution, enlisted partisan lawyers to do its bidding, circumvented established precedent to illegally obtain evidence, and misleadingly quoting banal testimony so that it could be labeled “perjury.” And, after having done so, prejudiced Ms. Maxwell’s right to a fair trial by improper extrajudicial statements. A. Abuse of the Civil Litigation Process to Gain a Tactical Advantage. As detailed in Ms. Maxwell’s Memorandum in Support of her Motion to Suppress all Evidence Obtained from the government’s Subpoena to J and to Dismiss Counts Five and Six, Ms. Maxwell was involved in lengthy, intrusive, and contentious litigation with ® A simple Google search for the name “Ghislaine Maxwell” on January 13, 2021 yielded 5,140,000 results in 0.56 seconds. Stories about Ms. Maxwell abound. Flight logs, complaints, deposition transcripts, and false accounts have been published and republished. ghislaine maxwell x § a Q All &) News [] Images [) Videos —] Books : More Settings Tools About 5,140,000 results (0.56 seconds) 15 DOJ-OGR-00002523