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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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
Entities connected to both Martindell and this stage.51 The Court

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
Bradley Edwards
PERSONJeffrey Pagliuca
PERSONLoretta A. Preska
PERSON
Colorado
LOCATION
Carpenter
PERSON
Eric Schmidt
PERSON
Supreme Court
ORGANIZATION
Stephen Hawking
PERSON