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nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher
nection with a protective order in a different case. The judge who presided over the civil case passed away in March 2019, and so then- Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision
d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher
arc inadmissible on hearsay or other grounds. See. e.g., United States v. Boyle, No. 08 CR 523 (CM), 2009 WL 484436, at •2 (S.D.N.Y. Feb. 24, 2009) (McMahon, J.) (quashing subpoena for investigative file as overbroad because although part of the investigative file "may be relevant to the case at bar," t
fs.' PRI Opp'n, at 27 (citing United States v. Yudung Zhu, No. 13 CR. 761, 2014 WL 5366107 (S.D.N.Y. Oct. 14, 2014) (Marrero, J.); United States v. Rajaratnam, 753 F. Supp. 2d 317 (S.D.N.Y. 2011) (I lolwell, J.); and United Stales v. McClure, No. CRIM.A. 10-028, 2010 WL 3523030 (E.D. La. Sept. 1, 2010)).)
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
.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Ck. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii
Entities connected to both Colleen McMahon and Rajaratnam

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
United States
LOCATIONthe Southern District
LOCATION
David Boies
PERSONSecond Circuit
ORGANIZATIONMartindell
PERSON
Supreme Court
ORGANIZATION
Carpenter
PERSON
Michael Cohen
PERSON
Stephen Hawking
PERSON
Eric Schmidt
PERSON
Boies Schiller
ORGANIZATIONthe Second Circuit's
ORGANIZATION
Virginia Giuffre
PERSONFisher
PERSONAndover Data Servs
ORGANIZATIONCanfield
PERSON
Rivera
PERSON