Epstein Secrets

epositions 4 C. The Settlement And Boles Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Sho

An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boles 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

ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge

n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained su

ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge

n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained su

ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge

n ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such mate

T OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES 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

897, 923 (1984). Here, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government act