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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
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 101 United States v. Wong, 431 U.S. 174 (1977) 101 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 43 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 139 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "Ni
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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t
Entities connected to both Martindell and Ying Lin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONSweet
PERSONColleen McMahon
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Southern District of New York
ORGANIZATIONFisher
PERSONthe Second Circuit's
ORGANIZATION
Bradley Edwards
PERSON
Colorado
LOCATION
Boies Schiller
ORGANIZATION
Eric Schmidt
PERSON
Supreme Court
ORGANIZATION
Carpenter
PERSONChemical Bank
ORGANIZATIONAndover Data Servs
ORGANIZATION