Epstein Secrets

ing on her motions to suppress and that it rule on the merits of her arguments before the trial on the non-perjury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

jury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

tly would violate due process for the government to be allowed to use that evidence at all, for any purpose. U.S. CONST. amend. V; United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

and suppress evidence by invoking their supervisory authority. Consistent with that principle, and given that this power is "sparingly exercised," Iambus, 897 F.3d at 401, (emphasis in original), this Court should not elect to do so here where the defendant has not established a violation of her Four

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

n J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon. Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East I Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 wvv.hmftaw.com jpogliucatihmflaw.com Re: United States v. Ghisiain

tly would violate due process for the government to be allowed to use that evidence at all, for any purpose. U.S. CONST. amend. V; United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobb

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i