Epstein Secrets

e's the only one who takes the blame for what happened").3 The government further asserts that Ms. Maxwell's position is not supported by subsequent Second Circuit cases that apply Annabi. (Opp. 5-6). But this argument simply begs the question. Although courts in this Circuit have applied Annabi to evaluate whe

States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 7 United States v. Rivera, 844 F.2d 916 (2d Cir. 1988) 9 ii EFTA00104413 United States v. Salamelz, 152 F.3d 88 (2d Cir. 1998) 7 United States v. Torres, 719 F.2d 549 (2d Cir. 1983) 15 iii EFTA00104414 Ghislaine Maxwell respectfully submit

the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00040678 deliberatel

the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compell

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00106053 Case 1:20-c

over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00066513 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00066524 deliberatel

over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00087254 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087265 deliberatel

over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The 4 EFTA00087233 Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly availabl

ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087244 deliberatel