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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
. See United States v. Salmonese,352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). Whe Regardless, the subsequent invitation de
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
See United States v. Sahnonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 5S Minor Victim-3 has been a she was invitedil
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
See United States v. Sahnonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 5S Minor Victim-3 has been a she was invitedil
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
See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). Accordingly, overt acts that may, on their own,
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
. See United States v. Salmonese, 352 F.3d 608, 614 (2d Cir. 2003) (citing Grunwald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 58 egar ess, e su sequent mvitatton emonstrate
Entities connected to both Martindell and Rutkoske

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