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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 21 of 26 plaintiff, Virginia Giuffre. During the course of that litigation, in 2016, Ms. Giuffre’s lawyers made overtures to the government seeking an indictment against Ms. Maxwell. At the same time, these lawyers were engaged in ongoing efforts to void the Epstein Non-Prosecution Agreement in litigation that was initiated in 2008. The government was the defendant and had actual notice of the claims made by Ms. Giuffre, her lawyers, and other Does about the allegations made in this criminal matter.’ The Assistant U.S. Attorney’s statements to [i Ree cannot be reconciled with the facts, many of which are detailed in the Office of Professional Responsibility Report concerning the government’s “2006-2008 Federal Criminal Investigation of Jeffrey Epstein” Ex. D and the volumes of pleadings filed in the CVRA litigation. Ms. Maxwell was known to the government for at least 10 years prior to the AUSA’s ex parte communication with B. The government’s Tactical Delay and the Civil Litigations. The Giuffre v. Maxwell defamation action has been in litigation for over five years. It has been advantageous to the government to have aggressive lawyers collecting information from Ms. Maxwell as part of civil discovery and disseminating that information to the public, as part of an ongoing campaign to vilify Ms. Maxwell. Using a friendly, ex-parte, x. the government obtained Ns eS 11: government has not, even after indicting Ms. Maxwell, moved to stay these civil proceedings. Instead, the government has used these lawyers to do their work, both in front of, and behind, the stage. These lawyers have made multiple, inappropriate, and prejudicial extrajudicial comments with no public rebuke from the government. The document unsealing process goes on, most 7 https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzhl7zdrzdgrbbs7yc6bfnszu-story.html. 16 DOJ-OGR-00002524