Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

endant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 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 SONY 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

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

endant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 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 SONY 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

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

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

.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Ck. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

endant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 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 SONY 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

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Ju

endant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 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 SONY 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

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

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

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

ver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish

.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

eration of the Court's July 23 Ruling Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Presk

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

ndment right of the accused to a fair trial. .. and the defendant's ... privacy interests.") (internal quotations omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010)); Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D. Conn. A

20-cr-00330-AJN Document 317 Filed 08/13/21 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY PILED DOC N: DATE FILED:8/13/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Jud

cking count and sex trafficking conspiracy count. The Court did not address the new charges in the April 16, 2021 Opinion & Order. On May 25, 2021, Maxwell filed another round of pretrial motions seeking to dismiss the S2 indictment in whole or in part and to compel discovery. Dkt. No. 292, 293. For app

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

the other hand, the Court must balance these interests against the harm to the Government from restricting its proof at trial. See United States v. Rajaratnam, No. 09-cr-1184 (RJH), 2010 WL 2788168, at *1 (S.D.N.Y. Jul. 13, 2010). In her previous motions, Maxwell argued that the Mann Act counts in the ind