Epstein Secrets

20-cr-00330-AJN Document 307 Filed 06/25/21 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District

dant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: Maxwell moves to suppress evidence obtained through a grand jury subpoena to a law firm involved in earlier civil litigation against her. She contends that

in the civil case. But because the Court finds no violation of the Fourth Amendment, it concludes that none of the documents should be suppressed. C. Maxwell is not entitled to suppression under due process or the Court's inherent authority Maxwell next argues that the materials must be suppressed becaus

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

e Court thus concludes that Maxwell is not entitled to suppress her deposition transcripts based on her right against compelled self-incrimination. B. Maxwell had no reasonable expectation of privacy in documents produced in civil litigation "The Fourth Amendment protects '[t]he right of the people to be

. No. 134-1 ¶ 13. A court may (as here) unseal documents covered by a civil protective order in the public interest. See Brown, 929 F.3d at 47; v. Marvell, 827 F. App'x 144, 145 (2d Cir. 2020); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006). Civil litigants have neither a reasonab

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL

OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DI

ork, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00086658 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 F

ury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients.M. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential di

tor, did Boies Schiller have any role instigating the Maxwell inquiry. I EFTA00086663 To paraphrase Mary Mc

or who was deposed in the case. The prosecutor defended the subpoena's breadth—which sought all "copies of discovery and related materials" irMv. Marvell—on the ground that the government simply had too little knowledge of what was in the law firm's files to craft a more narrowly tailored subpoena:

tein: International Moneyman of Mystery He's pals with a passel of Nobel Prize-winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But It wasn't until he flew Bill Clinton, Kevin Spatcy, and Chris Tucker to Africa on his private Boeing 7a7 that the world beg

e with links to Bill Clinton, Kevin Soucy, Robert Maxwell - and Launches Radical Emotional Prince Andrew'

CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But It wasn't until

townhouse a few blocks away. Epstein Is frequently seen around team with a hay- at coin* yang; women but Mar hat been no boldfaced name to replace Marvell. "You 'nay read about Jeffrey in these:ail column, but there Is mud: Rant to him than that; mys Jeffrey-7. lee& of tlw private *quite rem Leeds Weld

inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps

After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le

entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have

ked questions about his sexual abuse of young girls, including Jane Doe No. I, Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Marvell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte

LING PALM BEACH LLC OTTO,JONATHAN B MAXWELL,GERTRUDE COLEMAN,CATHERINE FISHER,K

RPHY,GARY JOHNSON,THEODORE M FISHER,MARCELLA PALMERIO,IMOGENE W BARBERIAN,HARRY

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE

TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE

TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE

TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boles Schiller's Refusal To Comply With The Protective Order 6 D. The

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 1