Epstein Secrets

orp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Factual Background The facts relevant to this Motion are descr

re v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016 EFTA00019001 --- PAGE BREAK --- Ghislaine Maxwell moves under the Fourth Amendment, Martindell v. Intl TeL & TeL Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury s

g modification of the Protective Order absent "good cause shown following notice to all parties and an opportunity for them to be heard"). Second, Martindell affords Maxwell a reasonable expectation of privacy. Martindell, 594 F.2d at 294. In Martindell, the Second Circuit held that "the proper procedure"

islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea

2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp.

ert W. Sweet in a civil defamation action, Giuffre v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Giuffre Action"), in order to permit the law firm of Boies Schiller Flexner LLP ("Boies Schiller") to comply with a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, V

otective order."); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)], that `this extraordinary writ [mandamus] would hardly be available ... wh

EFTA00011456 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six a

protective orders if their testimony were to be made available to the Government for criminal investigatory purposes in disregard of those orders." Martindell, 594 F.2d at 295-96. Parties thus rely on protective orders, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (S

islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea

overnment's investigation in this case was occasioned by Boies Schiller—a point to which I will return later in this opinion." Mot. Ex. G, p 12. 20 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). 18 EFTA00028951 --- PAGE BREAK --- Judge McMahon "returned" to that point when discussin

EFTA00029081 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six a

e The Fruits Of That Evidence 1. The role of protective orders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil di

EFTA00029820 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six a

e The Fruits Of That Evidence 1. The role of protective orders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil di