Epstein Secrets

ears found grooming behavior to be a means to "persuade, induce, or entice" minorsto engage in illegal sexual activity. See, e.g., United States v. Thompson, 896 F.3d 155, 173 (2d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition wou

d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorv

e, and the Court's inherent authority. However, Maxwell's motion turns on erroneous facts, runs afoul of controlling law, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martin

ars found grooming behavior to be a means to "persuade, induce, or entice" minors to engage in illegal sexual activity. See, e.g., United States v. Thompson, 896 F.3d 155, 173 (2d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition wou

d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorv

overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but

ars found grooming behavior to be a means to "persuade, induce, or entice" minors to engage in illegal sexual activity. See, e.g., United States v. Thompson, 896 F.3d 155, 173 (2d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition wou

d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorv

overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but

ars found grooming behavior to be a means to "persuade, induce, or entice" minors to engage in illegal sexual activity. See, e.g., United States v. Thompson, 896 F.3d 155, 173 (2d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition wou

d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorv

overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netburn concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, bu

1971) 207,211,217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3,2013) 281,284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v. T

4 8. Unsealing of Maxwell's Depositions. 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

71) 139, 141, 145 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 53 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 165 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 182, 189, 192 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 156 United Stat

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorve

uppression Motion Should Be Denied Maxwell seeks suppression of the evidence the Government obtained via a judicially authorized subpoena to under Martindell, the Fourth Amendment, Fifth Amendment, the Due Process clause, and the Court's inherent authority. However, Maxwell's motion turns on erroneous fa

71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8