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

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

Parties' reliance."). 79 EFTA00100046 cau PPIal (Id. washy a granrad issulaubeaurnalMI an In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martind ell, reversed the district court's decision granting the state Attorney General's motion to intervene to

her the protective order was improvidently granted or whether the government had made a showing of exceptionalcircumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification o fprotective orders where district court did not make an "express finding" of improvidenc

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

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://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

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

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

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

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://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

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

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

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

materials. Giuf•e v. 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

as "insist[ing] [a second meeting] never happened." 36 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://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7

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

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

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

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initi

grand jury that had issued a alliena for the production of documents as parl'of an ongoing ation5). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge Netburn

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, hftps://www.nydailynews.cominew-yorlc/ny-j effrey-epstein-maxwel I-case-20201013- jrnzhl7

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

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

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc

allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial

ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to

bpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell a

e application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffre

al by motion to quash or modify the subpoena ... or to seek permissive intervention in the private action.") (internal quotations omitted); but see Palmieri v. State of N Y., 779 F.2d 861, 862 (2d Cir. 1985) (considering appeal where the New York State Attorney General, rather than the subject of the subpoena, w

er is "improvidently granted" where the presiding judge "reasonably should have recognized that [it] would facilitate or further criminal activity." Palmieri, 779 F.2d at 865-66. But there is absolutely no evidence that the district court harbored any such realization; indeed, at the time Judge Sweet ent

has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand

ith a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Eps

l by motion to quash or modify the subpoena . .. or to seek permissive intervention in the private action.") (internal quotations omitted); but see Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (considering appeal where the New York State Attorney General, rather than the subject of the s

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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 FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH

(9th Cir. 2016) 4, 5, 11 Katz v. United States, 389 U.S. 347 (1967) 2, 6 Murphy v. Waterfront Comm 'n of New York Harbor, 378 U.S. 52 (1964) 2 Palmieri v. State of New York, 779 F.2d 861 (2d Cir. 1985) 14 People v. Gutierrez, 222 P.3d 925 (Cob. 2009) 10 People v. Mason, 989 P.2d 757 (Colo. 1999

passim iii EFTA00015306 --- PAGE BREAK --- Ghislaine Maxwell moves under the Fourth Amendment, Martind

s of that unlawful subpoena. FACTUAL BACKGROUND Ms. Maxwell's Motion under the Due Process Clause to Suppress

rom a grand jury subpoena it issued to arid to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. FACTUAL BACKGROUND Ms. Maxwell's Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6 sets forth the facts relevant to this motion. Ms. Maxwell incorporates

FFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee xX Defe

NIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee

enseaecneaesaeaesaeseesseneeseeaeens 12 O’Brien v. Alexander, 898 F.Supp. 162, 171 (S.D.N-Y. 1995) ooo. eesceseeceseerseeseeeseeereeeseeneeeeseees 30 Palmieri v. Defaria, 88 F.3d 136, 141 (2d Cir. 1996) oo... eee esseeecsseesseeneeceseeseeeseeeseeenseesseeseeesseees 33 People v Thomas, 21 N.Y .3d 226 (2013)

74) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Attorneys for Ghislaine Maxwell 37 HOUSE_OVERSIGHT_011470 --- PAGE BREAK --- CERTIFICATE OF SERVICE I certify that on March 17, 2017, I electronically served this Defendant’s R