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4 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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ly considered and approved such an outcome, or communicated such a promise to Epstein. Further still, the record in the civil case makes clear that USAO-SDFL's position was that the NPA did not bind other districts. In a July 5, 2013 brief, USAO-SDFL stated: [T]he Non-Prosecution agreement simply obligated
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
Entities connected to both Martindell and USAO-SDFL's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSONSweet
PERSONthe Southern District
LOCATION
United States
LOCATION
Boies Schiller
ORGANIZATIONJane Doe
PERSON
Southern District of New York
ORGANIZATION
Bradley Edwards
PERSONFisher
PERSONthe Second Circuit's
ORGANIZATIONChemical Bank
ORGANIZATION
Colorado
LOCATION
Carpenter
PERSON
Supreme Court
ORGANIZATION
Eric Schmidt
PERSON
Prince Andrew
PERSON