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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, A

SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S S

MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00097331 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORITIES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The

ably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller. The facts and law belie the government's claims. A. Maxwell has standing. The government's standing argument boils down to this: Maxwell cannot challenge the search because the material was in the possession

arpenter v. United States would have come out differently, since the defendant's historical cell-site location information was in the possession of MetroPCS and Sprint. 138 S. Ct. 2206, 2212 (2018). But the United States Supreme Court rejected application of the third-party doctrine for two reasons, as t

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, A

SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S S

ey S. Pagliuca Laura A. Mennin • er Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00097649 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORITIES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The

ably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller. The facts and law belie the government's claims. A. Maxwell has standing. The government's standing argument boils down to this: Maxwell cannot challenge the search because the material was in the possession

arpenter v. United States would have come out differently, since the defendant's historical cell-site location information was in the possession of MetroPCS and Sprint. 138 S. Ct. 2206, 2212 (2018). But the United States Supreme Court rejected application of the third-party doctrine for two reasons, as t

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, A

SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S S

57-7600 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00100287 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORITIES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The

ably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller. The facts and law belie the government's claims. A. Maxwell has standing. The government's standing argument boils down to this: Maxwell cannot challenge the search because the material was in the possession

arpenter v. United States would have come out differently, since the defendant's historical cell-site location information was in the possession of MetroPCS and Sprint. 138 S. Ct. 2206, 2212 (2018). But the United States Supreme Court rejected application of the third-party doctrine for two reasons, as t

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ead for new information!!! MetoPCS gives its customers Ponslutes to speak fieslyP with unlimited calls for one flat fee paid in advance of service. MetroPCS currenly operates in the greater metropolitan areas of Atlanta, Dallas/Ft. Watt Detroit, Sacramento and San Francisco as well as central and souther

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32: 0 0 6/18/2006 10:33: 0 0 6/18/2006 10:33: • 0 1 6/18/2006 10:33: • 0 1 6/18/2006 10:39: 0 0 6/18/2006 10:39: 0 0 EFTA01697073 MetroPCS Call Detail foe -125pgs 1-1-06 to 8-1-06.xls Page 99 of 125 BILLED PHONE CALL DATE TIME DIALED NUMBER DEST NUMBER DIR S MM SEC CALLER ID 6/1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (MN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FI

ork, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00018997 --- PAGE BREAK --- TABLE

ES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The Government's violation of the Fourth Amendment requires suppression 1 A. Maxwell has standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails 5 II. The Government's violation of M

ably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller. The facts and law belie the government's claims. A. Maxwell has standing. The government's standing argument boils down to this: Maxwell cannot challenge the search because the material was in the possession