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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
or sexual massages .. . you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
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
nt. 124 EFTA00095216 you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss
Entities connected to both Martindell and Cl Triumph Capital Grp.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONColleen McMahon
PERSONSweet
PERSON
United States
LOCATIONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONJane Doe
PERSONthe Second Circuit's
ORGANIZATIONFisher
PERSON
Bradley Edwards
PERSONLoretta A. Preska
PERSONJeffrey Pagliuca
PERSON
Colorado
LOCATION
Eric Schmidt
PERSON
Carpenter
PERSON
Supreme Court
ORGANIZATION
Stephen Hawking
PERSON