Epstein Secrets

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magistrate Juda jOrder On or about April 9, 201

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. n. Maxwell, No.20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://www.nydailynews.corninew-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzh17zdr

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

er assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot 3 at 2) (emphasis in orig

the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government

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

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

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

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

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

material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1

the need for a trial and are pleased with the result' , 33, had persuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For

rsuaded a judge to throw out a motion preventing her from suing British socialite Ghislaine Maxwell, 55, for defamation The defamation suit alleged Maxwell instructed her spokesman to attack honesty and truthfulness and to accuse her of lying For internal use only SDNY_GM_00059503 CONFIDENTIAL - PURS

87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_00059558 CONFIDE

UERQUE, NM 87111-8318 1602 PENNSYLVANIA ST NE APT E ALBUQUERQUE, NM 87110-5552 1501 TRAMWAY BLVD NE APT C206 ALBUQUERQUE, NM 87112-6108 14 MAX'WELL, GHISLAINE 116E 65TH ST 133-78-XXXX 12/1961 NOELLE NEW YORK, NY 10065- 12/1961 MAXWELL GHISLANE N 7007 For internal use only SDNY_GM_000595

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso

cution/non-prosecution of Epstein; b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 ogers, r lam Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information r

nment's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 oge

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not