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

l Evidence Obtained J the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: Alison Moe Maurene Comey Andrew Rohrbach Lam Pomerantz U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York NY 101)Y7 s/ Christian R. Everdell 29 EFTA00077604

of New York Notice of Electronic Filing The following transaction was entered on 4/1/2022 at 12:51 PM EDT and filed on 4/1/2022 Case Name: USA v. Maxwell Case Number: 1:20-cr-00330-VSB Filer: Document Number: No document attached NOTICE OF CASE REASSIGNMENT as to Ghislaine Maxwell, to Judge Vernon

1/2022 Case Name: USA v. Maxwell Case Number: 1:20-cr-00330-VSB Filer: Document Number: No document attached NOTICE OF CASE REASSIGNMENT as to Ghislaine Maxwell, to Judge Vernon S. Broderick. Judge Alison J. Nathan no longer assigned to the case. (bw) 1:20-cr-00330-VSB-1 Notice has been electronically maile

ument attached NOTICE OF CASE REASSIGNMENT as to Ghislaine Maxwell, to Judge Vernon S. Broderick. Judge Ali

[email protected] Maurene Ryan Comey maurene.comeyffusdoj.gesi, [email protected], USANYS.ECF@USDOLGOV Katielynn Boyd Townsend [email protected] Andrew Rohrbach [email protected], [email protected], [email protected] 1:20-cr-00330-VSB-1 Notice has been delivered by other means to: EFTA00155663

talk with you today. Looking forward to working with you and Alex going forward. I'm cc'ing AUSAs Lara Pomerantz and Andrew Rohrbach, who tried the Maxwell case with me. I took the lead on discovery in the case, so I'm happy to be your primary point of contact about inquiries regarding the case file. B

SAs Lara Pomerantz and Andrew Rohrbach, who tried the Maxwell case with me. I took the lead on discovery in th

s very much, Kristen! Great to talk with you today. Looking forward to working with you and Alex going forward. I'm cc'ing AUSAs Lara Pomerantz and Andrew Rohrbach, who tried the Maxwell case with me. I took the lead on discovery in the case, so I'm happy to be your primary point of contact about inquiries rega