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rd the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party shou
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00040678 deliberatel
rd the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Cap., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party shoul
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00106053 Case 1:20-c
rd the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party shou
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00066524 deliberatel
rd the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party shou
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087265 deliberatel
rd the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party shou
ority. Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government 15 EFTA00087244 deliberatel
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
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
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
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
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
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
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
e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively
Entities connected to both Martindell and Salamelz

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONSecond Circuit
ORGANIZATIONColleen McMahon
PERSON
United States
LOCATIONthe Southern District
LOCATION
Boies Schiller
ORGANIZATIONSweet
PERSONthe Second Circuit's
ORGANIZATIONFisher
PERSON
Eric Schmidt
PERSON
Carpenter
PERSON
Supreme Court
ORGANIZATIONAndover Data Servs
ORGANIZATIONJane Doe
PERSON
Southern District of New York
ORGANIZATIONCanfield
PERSON
Colorado
LOCATION