Epstein Secrets

it have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access t

The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28, 2019 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netbum United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci

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

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

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

full compliance.33 (Exs. 8 & 9). Accordingly, the Government applied a pate and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo

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

ll compliance.33 (Exs. 8 & 9). Accordingly, the Government applied ex parte and under seal to each relevant court (Judge Sweet and Magistrate Judge Sarah Netbum, respectively) to request that each court modify the respective protective orders to permit compliance with the subpoenas. (Def. Mot. 3, Ex. C). Fo