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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
or sexual massages .. . you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
nt. 124 EFTA00095216 you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
Entities connected to both Subpoena Duces and Cl Triumph Capital Grp.

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