Epstein Secrets

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"

, 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. Maxwell. In

ection with a lawsuit in reasonable reliance upon a Federal Rule of Civil Procedure 26(c) protective order, the information must remain sealed. See Martindell v. Intl TeL & TeL Corp., 594 F.2d 291, 296 (2d Cir. 1979); see id. at 297- 98 (Medina, J., concurring) (noting "overriding policy in favor of enforci

, and trade secrets). Ms. Maxwell is aware, based on publicly reported statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is

on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding

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

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two

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

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two

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