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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
ecause double jeopardy is meant to protect a defendant from successivepunishments for the same offense, a multiplicitous count does not violate the Clause unless and until sentence is imposed. See Josephberg, 459 F.3d at 355 ("Where there has been no prior conviction or acquittal, the Double Jeopardy
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
cause double jeopardy is meant to protect a defendant from successive punishments for the same offense, a multiplicitous count does not violate the Clause unless and until sentence is imposed. See Josephberg, 459 F.3d at 355 ("Where there has been no prior conviction or acquittal, the Double Jeopardy
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
cause double jeopardy is meant to protect a defendant from successive punishments for the same offense, a multiplicitous count does not violate the Clause unless and until sentence is imposed. See Josephberg, 459 F.3d at 355 ("Where there has been no prior conviction or acquittal, the Double Jeopardy
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
cause double jeopardy is meant to protect a defendant from successive punishments for the same offense, a multiplicitous count does not violate the Clause unless and until sentence is imposed. See Josephberg, 459 F.3d at 355 ("Where there has been no prior conviction or acquittal, the Double Jeopardy
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
cause double jeopardy is meant to protect a defendant from successive punishments for the same offense, a multiplicitous count does not violate the Clause unless and until sentence is imposed. See Josephberg, 459 F.3d at 355 ("Where there has been no prior conviction or acquittal, the Double Jeopardy
Entities connected to both Martindell and Clause

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
United States
LOCATIONSweet
PERSONthe Southern District
LOCATIONColleen McMahon
PERSON
Southern District of New York
ORGANIZATIONJane Doe
PERSON
Bradley Edwards
PERSON
Colorado
LOCATIONthe Second Circuit's
ORGANIZATIONJeffrey Pagliuca
PERSONFisher
PERSONLoretta A. Preska
PERSON
Supreme Court
ORGANIZATION
Stephen Hawking
PERSON
Carpenter
PERSON
Eric Schmidt
PERSON