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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page6of17 tried, convicted, and condemned in the court of public opinion. Based on widespread coverage of her extraordinary and miserable conditions of pretrial detention, unsworn “jurors” likely believe sentence has already been imposed. The pretrial publicity and publications are far too extensive to list. As of this writing, a simple Internet search by Google yields the following: =" Ghislaine Maxwell: “about 4,590,000 results (0.77 seconds)” " Jeffrey Epstein: “about 25,800,000 results (0.87 seconds)” Neither Ms. Maxwell nor her undersigned defense team has ever spoken to the media and have not contributed to the polluting effect of this unprecedented coverage. In addition, there have been numerous books, podcasts, and documentaries published and broadcast about Ms. Maxwell, Epstein, and the allegations in this case. The following is just a small sample of recent publications concerning Ms. Maxwell: Documentaries " Jeffrey Epstein: Filthy Rich (Netflix) " Notorious: Ghislaine Maxwell (ABC 20/20) « Epstein’s Shadow: Ghislaine Maxwell (Peacock) Podcasts: " Chasing Ghislaine: The Untold Story of the Woman in Epstein’s Shadow (Vicky Ward) " Hunting Ghislaine (John Sweeney) " The Ghislaine Maxwell Spiral (Audible) Books: " Ghislaine Maxwell (Steve H. Dwight) " Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein and Ghislaine Maxwell (Bradley Edwards) " Trash: Encounters with Ghislaine Maxwell (Christina Oxenberg) = Perversion of Justice (Julie K. Brown) DOJ-OGR-00005211