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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 22 of 26 recently attracting approximately 1,000 prurient listeners, some of whom illegally broadcast the proceedings on YouTube.® The effect of all of this on a potential juror is not lost on the government and it has been to its tactical advantage to allow as much negative press as possible, fomented by Government shills. C. The Timeline Relating to the Accuser-2 Civil Litigation. In the civil matter, Farmer v. Indyke, Case No. 19-cv-10475 (LGS), plaintiff Annie Farmer (presumed Accuser- 2) discussed in the Indictment, was represented by the same attorneys, David Boies and Sigrid McCawley of Boies, Schiller & Flexner LLP (“BSF”) who also represented Ms. Virginia Giuffre in her defamation action. Shortly after counsel’s appearance on behalf of Ms. Maxwell on March 4, 2020, BSF served on Ms. Maxwell a Notice of Deposition for April 29, 2020, without ever having conferred with counsel for available dates. Later, BSF amended their notice of deposition to May 18, or offered dates of May 21, 26, 27 and 28" (and demanded an in-person deposition despite the raging COVID pandemic in New York). Ms. Maxwell filed a Letter Motion on May 13, 2020, requesting a stay of discovery in the case due, in part, to the U.S. Attorney’s Southern District of New York’s announcements of its “ongoing” criminal investigation into alleged Epstein “co-conspirators,” presumed to include Ms. Maxwell. /d., Dkt. 68. In his response opposing the stay of discovery, Mr. Boies represented to the court that “Maxwell has provided no information about the subject matter of the criminal investigation into Mr. Epstein’s co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District’s investigation.” /d., Dkt. 72. At the time he wrote that statement, Mr. Boies knew, and Ms. Maxwell and her counsel did not, that his client, plaintiff Annie Farmer, was herself participating in efforts to criminally prosecute Ms. 8 See https://www.theguardian.com/us-news/202 1 /jan/19/ghislaine-maxwell-court-proceeding- anon. 17 DOJ-OGR-00002525