Epstein Secrets

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

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

s Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five And Six upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 s/ Christian R. Everdell 18 EFTA00011474

. CONST. amend. IV passim U.S. CONST. amend. V passim iii EFTA00015306 --- PAGE BREAK --- Ghislaine Maxwell moves under the Fourth Amendment, Martindell v. Intl TeL & TeL Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury s

uit's II EFTA00015317 --- PAGE BREAK --- decision in Martindell v. International Telephone & Telegraph Corp. and violated Maxwell's rights. In Martindell, the government tried to obtain deposition transcripts of twelve individuals deposed in a private shareholders' derivative lawsuit. 594 F.2d at 292-

and the Fi h Amendment to Suppress All Evidence Obtained from the government's Subpoena t and to Dismiss Counts Five and Six upon the following: U.S. Attorney's Office SDNY New York, NY 10007 s/ Christian R. Everdell 18 EFTA00015324

re v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016 EFTA00019001 --- PAGE BREAK --- Ghislaine Maxwell moves under the Fourth Amendment, Martindell v. Intl TeL & TeL Corp., 594 F.2d 291 (2d Cir. 1979), and the Fifth Amendment, to suppress all evidence the government obtained from a grand jury s

g modification of the Protective Order absent "good cause shown following notice to all parties and an opportunity for them to be heard"). Second, Martindell affords Maxwell a reasonable expectation of privacy. Martindell, 594 F.2d at 294. In Martindell, the Second Circuit held that "the proper procedure"

mendment to Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 s/ Christian R. Everdell 15 EFTA00019016

District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut

dmits the following facts are true: • On February 29, 2016, AUSA M, the Human Trafficking Coordinator and Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan Pottinger, and Brad Edwards, who represented M,

overnment's investigation in this case was occasioned by Boies Schiller—a point to which I will return later in this opinion." Mot. Ex. G, p 12. 20 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). 18 EFTA00028951 --- PAGE BREAK --- Judge McMahon "returned" to that point when discussin

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

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

ppeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the governme

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