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a witness against himself, within the meaning of the fifth amendment." (Det. Mot. 11 at 15) (quoting Boyd, 116 U.S. at 634-35). In In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, the Second Circuit ruled that the Fifth Amendment does not protect the contents of private papers that are not business d
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question forpost hoc ambiguity,"Strohm, 671 F.3d at 1178. A reasonable j
entitled to rely upon the enforceability of a protective order against any third parties, including the Government." Id.; see also In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221, 1224-25 (2d Cir. 1991) ("The Martindell test [ ] does not transform a protective order into a grant of im
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
entitled to rely upon the enforceability of a protective order against any third parties, including the Government." Id.; see also In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221, 1224-25 (2d Cir. 1991) ("The Martindell test [ ] does not transform a protective order into a grant of im
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
s the proper remedy.39 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the gover
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
entitled to rely upon the enforceability of a protective order against any third parties, including the Government." Id.; see also In re Grand Jury Subpoena Duces Tecum Dated Apr 19, 1991, 945 F.2d 1221, 1224-25 (2d Cir. 1991) ("The Martindell test [ ] does not transform a protective order into a grant of imm
rguments only underscore the principle that perjury prosecutions are an inquiry into "the natural meaning in the context in which words were used," Bonacorsa, 528 F.2d at 1221, and not an opportunity for defense counsel to "plumb[] a question for post hoc ambiguity," Strohm, 671 F.3d at 1178. A reasonable
Entities connected to both Subpoena Duces and Bonacorsa

Jeffrey Epstein
PERSONthe Southern District
LOCATION
David Boies
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSweet
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSONMartindell
PERSON
Scarlett Johansson
PERSON
Heath
PERSONStokes
PERSONFisher
PERSONMaria Farmer
PERSONAmato
PERSON
Bradley Edwards
PERSON
Carpenter
PERSON
Southern District of New York
ORGANIZATION
Supreme Court
ORGANIZATIONStatistical Tabulating Corp.
ORGANIZATION