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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
otes of the February 29 meeting show that Boies Schiller promised to send the government "depositions," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the government had not yet charged 10 EFTA00100301 Maxwell with perjury.; There are compelling reasons, the
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
otes of the February 29 meeting show that Boies Schiller promised to send the government "depositions," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the government had not yet charged 10 EFTA00097345 Maxwell with perjury.3 There are compelling reasons, the
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
otes of the February 29 meeting show that Boies Schiller promised to send the government "depositions," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the government had not yet charged 10 EFTA00097663 Maxwell with perjury.3 There are compelling reasons, the
Entities connected to both Manindell and David Boies later

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