5
Shared Docs
5
Same-Page
5 / 5
Mentions
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
ing concealment or "cover-ups" were not obviously within the scope of the charged conspiracy to defraud the United States by impairing and impeding the Immigration and Naturalization Service. Id. at 20, 24-26. Although the Court denied the motion to strike the alleged surplusage, it ordered the prosecution to provide a bill of particula
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but
ing concealment or "cover-ups" were not obviously within the scope of the charged conspiracy to defraud the United States by impairing and impeding the Immigration and Naturalization Service. Id. at 20, 24-26. Although the Court denied the motion to strike the alleged surplusage, it ordered the prosecution to provide a bill of particula
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netbum concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, but
ing concealment or "cover-ups" were not obviously within the scope of the charged conspiracy to defraud the United States by impairing and impeding the Immigration and Naturalization Service. Id. at 20, 24-26. Although the Court denied the motion to strike the alleged surplusage, it ordered the prosecution to provide a bill of particula
uppression Motion Should Be Denied Maxwell seeks suppression of the evidence the Government obtained via a judicially authorized subpoena to under Martindell, the Fourth Amendment, Fifth Amendment, the Due Process clause, and the Court's inherent authority. However, Maxwell's motion turns on erroneous fa
ing concealment or "cover-ups" were not obviously within the scope of the charged conspiracy to defraud the United States by impairing and impeding the Immigration and Naturalization Service. Id. at 20, 24-26. Although the Court denied the motion to strike the alleged surplusage, it ordered the prosecution to provide a bill of particula
overnment's arguments for exceptional circumstances and compelling need as relying on "the general desire for secrecy" and "unpersuasive" under the Martindell standard. (Id. at 6). Judge Netburn concluded that "the Government must demonstrate not that this investigation is an extraordinary circumstance, bu
ing concealment or "cover-ups" were not obviously within the scope of the charged conspiracy to defraud the United States by impairing and impeding the Immigration and Naturalization Service. Id. at 20, 24-26. Although the Court denied the motion to strike the alleged surplusage, it ordered the prosecution to provide a bill of particula
Entities connected to both Martindell and the Immigration and Naturalization Service

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
United States
LOCATIONColleen McMahon
PERSONSweet
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Southern District of New York
ORGANIZATION
Bradley Edwards
PERSON
Supreme Court
ORGANIZATIONFisher
PERSONthe Second Circuit's
ORGANIZATIONLoretta A. Preska
PERSON
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Eric Schmidt
PERSON
Carpenter
PERSON
Stephen Hawking
PERSON