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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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
Entities connected to both Subpoena Duces and the Federal Rules of Evidence and Procedure

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