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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
ws in the context of child abuse prosecutions are not in conflict with constitutional notice requirements."' Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)). The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates
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
ows in the context of child abuse prosecutions are not in conflict with constitutional notice requirements!" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)). The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates
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
ows in the context of child abuse prosecutions are not in conflict with constitutional notice requirements!" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)). The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates
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
ws in the context of child abuse prosecutions are not in conflict with constitutional notice requirements.'" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)). The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates
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
ows in the context of child abuse prosecutions are not in conflict with constitutional notice requirements!" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)). The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates
Entities connected to both Martindell and Valentine v. Konteh

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSONSweet
PERSON
United States
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Southern District of New York
ORGANIZATIONthe Second Circuit's
ORGANIZATIONFisher
PERSON
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSONLoretta A. Preska
PERSON
Eric Schmidt
PERSON
Carpenter
PERSON
Supreme Court
ORGANIZATIONChemical Bank
ORGANIZATION