Epstein Secrets

, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every other civil case in the Southern District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in v. Maxwel

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every other civil case in the Southern District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in v. Maxwel

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every other civil case in the Southern District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in Giuffre v.

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

w, the motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is entirely irrelevant to this case, and the defendant's motion fails as a matter of law. Second, the indictment is timely under 18 U.S.C

atively limited, due to the confidential nature" of the litigation. (Id. at 2 n.1). The Government also submitted that the court need not employ the Manindell balancing test to evaluate the Government's ability to obtain access to materials covered by a protective order because (1) the Martindell balancin

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu