Epstein Secrets

2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp.

USA back to court for one reason. "I'll be very up-front with you," she said. Mot. Ex. E, p 2. 14 EFTA00077589 I want to make sure I'm not in a Chemical Battk[15] kind of situation, so I would like to know about contacts between the United States Attorney's Office and the Boies Schiller firm prior t

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

DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J

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

DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J

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

ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub

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

NY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Def. Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief Judg

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

s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m