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Case 1:20-cr-00330-PAE Document 342 Filed 10/13/21 Page /7of17 " Ghislaine Maxwell: The Rise and Fall of Manhattan’s Most Famous Socialite (Nigel Cawthorne) e The Spider: Insider the Criminal Web of Jeffrey Epstein and Ghislaine Maxwell (Barry Levin) e Jeffrey Epstein’s Other Women: Behind Ghislaine Maxwell (Lisa Tait) e The Jeffrey Epstein Case: What We Do and Don’t Know About Jeffrey Epstein and Ghislaine Maxwell (Stephen Wright) Much of the pretrial reporting, publications, and broadcasts refer to Epstein’s 2008 case in Florida and the public outrage over his charges, plea deal, the leniency he received. The aftermath of this coverage resulted in the resignation of Labor Secretary Alex Acosta, former U.S. Attorney of the Southern District of Florida, whose office was the subject of an inquiry conducted by the Department of Justice’s Office of Professional Responsibility (““OPR’’) concerning the federal criminal investigation of Epstein and its interactions with victims. OPR released a report of its investigation in November 2020, which again led to a series of media articles about Epstein’s conduct and the appropriateness of the deal he received. The effect of such recurring reporting regarding Epstein has had an incalculable spillover effect that has indelibly stained Ms. Maxwell and significantly impacted her ability to receive a fair trial by an impartial jury. B. Allegations of Sex Abuse Abound in New York Ms. Maxwell approaches trial under the cloud of massive negative publicity focused on one of the most sensational, hot-button social issues in recent years — sexual harassment and abuse of females of all ages, including inappropriate sexual contact with minors. High-profile investigations, prosecutions, and trials involving politicians, moguls and celebrities are daily occurrences. New York has been the venue for some of the most notorious events, including but hardly limited to the recent investigation and resignation of Governor Andrew Cuomo and trials and convictions of Harvey Weinstein and R. Kelly. These are not rare occurrences. Consider the DOJ-OGR-00005212