Epstein Secrets

Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pretrial Disclosures II. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Motion to Dism

h Six of the Superseding Indictment for Pre- Indictment Delay 8. Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous 9. Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pr

losures EFTA00097329 The Honorable Alison J. Nathan March 15, 2021 Page 2 II. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Reply Memoran

tment for Pre-Indictment Delay 8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count Three of the Superseding Indictment as Multiplicitous 9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as It Was Obtained in Violation of the Sixth Amendment 10. Reply Me

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

no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am multiplicitous. (Def. Mot. 8). Because the Second Circu

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

ndictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. The Defendant's Various Disclosure Motions Should be Denie

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

no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are multiplicitous. (Def. Mot. 8). Because the Second Circ

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

ndictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. The Defendant's Various Disclosure Motions Should be Denie

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

no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are multiplicitous. (Def. Mot. 8). Because the Second Circ

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

ndictment 157 A. Relevant Facts 157 B. Applicable Law 159 C. Discussion 160 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 169 C. Discussion 171 X. The Defendant's Various Disclosure Motions Should be Denie

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

the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are multiplicitous. (Def. Mot. 8). Because the Second Circ

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

ictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. The Defendant's Various Disclosure Motions Should be Den