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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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
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
ine[d] Ms. Maxwell's invitation to reconsider its order" and noted that the defendant had both filed a suppression motion and available tools under the Federal Rules of Evidence and Procedure. (See 15 Civ. 7433 (LAP), Dkt. No. 1211 at 3, 5). The portion of the July 2016 deposition transcript that forms the basis of Count Six that has been
Entities connected to both Martindell and the Federal Rules of Evidence and Procedure

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