Epstein Secrets

lentine, 820 F.2d 565 (2d Ck. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00011454 --- PAGE BREAK --- Other Authorities Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue J

o prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the con

lentine, 820 F.2d 565 (2d Ck. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00029079 --- PAGE BREAK --- Other Authorities Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue J

oena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protecti

An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boies Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence 11 I. The role of protective orders in civil litigation 11 2. The go

lentine, 820 F.2d 565 (2d Ck. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii EFTA00029818 --- PAGE BREAK --- Other Authorities Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue J