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as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary
vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M
as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary
vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M
as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary
vernment disclosed the 90,000 pages of material it obtained from Boies Schiller.2 The government's due process violation warrants suppression. E.g., Raheem v. Kelly, 257 F.3d 122, 135 (2d Cir. 2001) (suppression for due process violation). Second, because the government violated Martindell not only by denying M
Entities connected to both Manindell and Raheem v. Kelly

Ghislaine Maxwell
PERSON
Carpenter
PERSONSweet
PERSON
Jeffrey Epstein
PERSONStokes
PERSON
David Boies
PERSON
Heath
PERSONJeffrey Pagliuca
PERSONthe Southern District
LOCATIONColleen McMahon
PERSONSubpoena Duces
PERSON
Julie K. Brown
PERSON
Schiller
PERSONStephen Rex Brown
PERSON
Stephen Hawking
PERSONLoretta A. Preska
PERSONSecond Circuit
ORGANIZATION
Michael Cohen
PERSONDarren Indyke
PERSONEmmy Taylor
PERSON