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and suppress evidence by invoking their supervisory authority. Consistent with that principle, and given that this power is "sparingly exercised," Iambus, 897 F.3d at 401, (emphasis in original), this Court should not elect to do so here where the defendant has not established a violation of her Four
e, and the Court's inherent authority. However, Maxwell's motion turns on erroneous facts, runs afoul of controlling law, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martin
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
Page: EFTA00011467 →arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i
Page: EFTA00011471 →'s motions to suppress allege violations of the due process clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Martindell v. International Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). If this Court agrees with Ms. Maxwell's arguments, not only will it suppress all 90
Page: EFTA00027170 →tly would violate due process for the government to be allowed to use that evidence at all, for any purpose. U.S. CONST. amend. V; United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i
Page: EFTA00027172 →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
Page: EFTA00029092 →arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i
Page: EFTA00029096 →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
Page: EFTA00029831 →arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i
Page: EFTA00029835 →Entities connected to both Iambus and Martindell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONSecond Circuit
ORGANIZATIONColleen McMahon
PERSON
Boies Schiller
ORGANIZATION
United States
LOCATIONJane Doe
PERSONJeffrey Pagliuca
PERSONChemical Bank
ORGANIZATION
Colorado
LOCATIONthe Second Circuit's
ORGANIZATION
Stephen Hawking
PERSON
Denver
LOCATION
Schiller
PERSON
Valentine
PERSONLaura Menninger
PERSONGhailani
PERSONStephen Rex Brown
PERSON