DOJ-OGR-00010451.jpg

Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 5 of 77

conspirators or accomplices of Epstein in connection with his controversial Florida plea deal, and although three of those same women were anonymously referenced in the 2019 SDNY indictment charging Epstein, the government chose not to prosecute any of them. Instead, the spotlight turned to Ghislaine Maxwell, with whom Epstein had had a relationship that was long since over and who was not named in the Florida “sweetheart” deal.

Ms. Maxwell did not appear in the 2019 SDNY indictment against Epstein, nor was she the subject of the 2007 SDFL grand jury presentation. Nevertheless, the government pivoted to Ms. Maxwell, who up to that point had never been the focus of any criminal prosecution for these events, and spent the next year investigating her. In doing so, SDNY had to reach back to events that were over 20 years old, a decade before the conduct that was the subject of the SDFL prosecution and the 2019 Epstein indictment. Almost a year to the day after Epstein’s arrest, SDNY’s Acting U.S. Attorney put the timing of Ms. Maxwell’s prosecution and the extreme age of the charges against her in context:

We were working hard on this investigation this past year. It’s not easy to put together a case that goes back that far, but it was nothing other than we did the investigation and we were ready at this time to proceed.³

The entire focus of the accusations initially aimed at Epstein were now centered on one defendant alone – Ghislaine Maxwell – at a time when she was already being vilified in the press and the public domain. The media coverage was relentless and voluminous: dozens of broadcast documentaries, tens of streamed videos and podcasts, and publication of some 50 books and thousands of superficially written articles. The tsunami of one-sided, overwhelmingly negative coverage about Ms. Maxwell that followed the arrest and death of Epstein presented Ms. Maxwell as a caricature of evil, a depiction that has inevitably shaped the public’s opinion of her. And the

³ https://www.youtube.com/watch?v=E7J4ReLHvqg, at 8:06 -8:23 (emphasis added)

4

DOJ-OGR-00010451