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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 inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court sho
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 inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court sho
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 inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court sho
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 inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court sho
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 inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court sho
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
et R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) 24 Rea v. United States, 350 U.S. 214 (1956)
Entities connected to both Ghislaine Maxwell and McNabb

Jeffrey Epstein
PERSON
United States
LOCATION
NEW YORK NY
LOCATIONthe Southern District
LOCATION
Julie K. Brown
PERSON
David Boies
PERSONSecond Circuit
ORGANIZATION
Robert Gates
PERSON
Supreme Court
ORGANIZATION
ALISON J. NATHAN
ORGANIZATIONFisher
PERSONColleen McMahon
PERSON
Eric Schmidt
PERSON
Boies Schiller
ORGANIZATIONMartindell
PERSONUSDC SONY
ORGANIZATION
Carpenter
PERSON
Lugosch
PERSONSalameh
PERSONOnondaga
LOCATION