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Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page5of7 Page 5 otherwise making wholly inappropriate comments to the press? For example, Spencer Kuvin (who represents some of Maxwell’s accusers) was interviewed for a recent show on Peacock called Epstein’s Shadow: Ghislaine Maxwell, which aired June 24, 2021. On Episode 3, Mr. Kuvin, who is identified as “Victim’s Attorney,” stated: “When you capture someone like [Ghislaine Maxwell] I don’t besmirch the U.S. Government from taking a victory lap. To be able to come back one year later and say ‘we’ve got the co-conspirator’, they wanted a little good press, as well they should. Take her down and embarrass the hell out of her. It’s what she deserves.” In another example, Brad Edwards, counsel to numerous accusers, changed the subtitle of his book Relentless Pursuit after Ms. Maxwell’s arrest from “My fight for the victims of Jeffrey Epstein” to “My fight for the victims of Jeffrey Epstein and Ghislaine Maxwell.” These examples do not amount to a drop in the bucket of the overwhelming press against Ms. Maxwell, which has been instigated or fueled by the Government and its witnesses. The “circus atmosphere” and “hostile” press that led to a reversal in the Sam Sheppard case are no match for what is occurring here. See Sheppard v. Maxwell, 384 U.S. 333 (1966) (reversing conviction based on hostile television and radio reporting of case: “Given the pervasiveness of modern communications and the difficulty of effacing prejudicial publicity from the minds of the jurors, the trial courts must take 6 There are countless other examples of the accusers’ lawyers appearing on TV, podcasts, radio, print (including writing books about the case), and social media, making inflammatory and many times, untrue statements that will make it impossible for Ms. Maxwell to receive a fair trial (some of which occurred after the Court’s Order about speaking with the media). See, e.g., Armchair Expert Podcast, August 6, 2020, Interview with Brad Edwards, counsel to accusers (“Q. How do you explain or what is your theory on Ghislaine Maxwell? Brad Edwards: So she needed money and Epstein needed connections. They were kind of the perfect pair. And then she realized, hey, this is this guy who has this crazy sex addiction that I can’t fulfill. And I think she would have done anything for him. And so she starts feeding him and just fuels the addiction. Without her, there would be no Jeffrey Epstein, we wouldn’t be talking. None of this would have happened. ... She created him. The first people that were brought to him to start this pyramid, they were brought by her. None of this could have grown. He could not have become who he was without her. She created the monster, no doubt about it.”); BBC Panorama, December 2, 2019, interview with David Boies (“I must say I think she is very culpable. She was a central part of the Epstein sex trafficking operation. Er, she played an important role in recruiting, grooming, manipulating. Host: She denies all of this of course. [10 seconds of silence] Boies: Um, if you say so.”); David Boies at press conference on the courthouse steps after the arraignment, April 24, 2021 (urging listeners not to have sympathy for Ms. Maxwell despite her conditions of confinement and her frail appearance); Sigrid McCawley, Lifetime, Surviving Jeffrey Epstein, August 15, 2020 (“Ghislaine was the master.”). DOJ-OGR-00004959