Epstein Secrets

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 DUE PROCESS CLAUSE TO SUPPRESS A

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 DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DI

. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed. R. Civ. P. 5.2 19 N.

ause the government was attempting to deprive Maxwell of notice and an opportunity to be heard); Martindell, 594 F.2d at 294; see U.S. CONST. amend. V. Maxwell also had a privacy interest in the materials subject to the subpoena, including most especially her deposition transcripts. Mot. Ex. A (defining "c

F.2d 1207, 1216 (7th Cir. 1980). In United States v. Cortina, a magistrate issued a search warrant based upon an affidavit subscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Secon

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 DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDE

Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00028929 --- PAGE BREAK --- Table

ts Fable of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's Defenses Are Worthy of Belief, the Government Still

F.2d 1207, 1216 (7th Cir. 1980). In United States v. Cortina, a magistrate issued a search warrant based upon an affidavit subscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Id. at 1208. Unbeknownst to Agent Stewart, Agent Second Circuit in

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 DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDE

& GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00029100 --- PAGE BREAK --- Table

ts Fable of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's Defenses Are Worthy of Belief, the Government Still

F.2d 1207, 1216 (7th Cir. 1980). In United States v. Cortina, a magistrate issued a search warrant based upon an affidavit subscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Secon