Epstein Secrets

harged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

4 8. Unsealing of Maxwell's Depositions. 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

ismissal of an indictment filed within the statute of limitations must establish that the Government acted intentionally, scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The de

not been dismissed on other grounds." (Def. Mot. 7 at 1). As noted above, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial, consistent with whatever schedule the parties agree upon or this Court sets. The Court should re

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. The defe

. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni

74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Applicable Law 76 b. Discussion 79 2. Maxwell's Fourth Amendment Claim Fails 8

10 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994) passim Franks v. Delaware, 438 U.S. 154 (1978) 18 Giglio v. U.S., 405 U.S. 150 (1972) 16 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6 Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260 (E.D. Pa.

protective orders if their testimony were to be made available to the Government for criminal investigatory purposes in disregard of those orders." Martindell, 594 F.2d at 295-96. Parties thus rely on protective orders, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (S

10 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994) passim Franks v. Delaware, 438 U.S. 154 (1978) 18 Giglio v. U.S., 405 U.S. 150 (1972) 16 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6 Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260 (E.D. Pa.

e The Fruits Of That Evidence 1. The role of protective orders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil di

10 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994) passim Franks v. Delaware, 438 U.S. 154 (1978) 18 Giglio v. U.S., 405 U.S. 150 (1972) 16 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6 Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260 (E.D. Pa.

e The Fruits Of That Evidence 1. The role of protective orders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil di