Epstein Secrets

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

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

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

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

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

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

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

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

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

stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con

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

ess attaches, and did not abuse its discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption of access." Giuffre v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 3).43 On October 22, 2020, the defendant's April 2016 deposition was publicly filed. (See 15 Civ. 7433 (L

Count Six, stating that the "testimony is .. . far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

e in the grant of the order or some extraordinary circumstance or compelling need.' SEC v. TheStreet.com, 273 F.3d 222, 229 (2d Cir. 2001) (quoting Martindell v. IT&T Corp., 594 F.2d 291, 296 (2d Cir. 1979)). Here, two 11 EFTA00073270 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 12 of 14 ci

mechanism. See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 444 (S.D.N.Y. 2019), rev'd on other grounds, Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019); Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (S.D.N.Y. Nov. 2, 2016), ECF No. 496 (Opinion Granting Dershowitz Motion to Intervene); Giuffre v. Maxwell, No. 15 Civ. 743