Epstein Secrets

ain silent. U.S. CONST. amends. V, VI; Rock v. Arkansas, 483 U.S. 44, 51 (constitution guarantees a defendant the right to testify in her defense); Brown v. Artuz, 124 F.3d 73, 78 (2d Cir. 1997) (wavier of the right to testify must be knowing and voluntary). Ms. Maxwell's decision whether to testify

tly would violate due process for the government to be allowed to use that evidence at all, for any purpose. U.S. CONST. amend. V; United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

ain silent. U.S. CONST. amends. V, VI; Rock v. Arkansas, 483 U.S. 44, 51 (constitution guarantees a defendant the right to testify in her defense); Brown v. Artuz, 124 F.3d 73, 78 (2d Cir. 1997) (wavier of the right to testify must be knowing and voluntary). Ms. Maxwell's decision whether to testify

tly would violate due process for the government to be allowed to use that evidence at all, for any purpose. U.S. CONST. amend. V; United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

and suppress evidence by invoking their supervisory authority. Consistent with that principle, and given that this power is "sparingly exercised," Iambus, 897 F.3d at 401, (emphasis in original), this Court should not elect to do so here where the defendant has not established a violation of her Four

--- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 510 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

--- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 510 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i

--- PAGE BREAK --- TABLE OF AUTHORITIES Cases Benkovitch v. Gorilla, Inc., No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) 17 Brown v. Maxwell, 929 F.3d 41 (2d Ck 2019) 3, 6 Chambers v. NASCO, Inc., 510 U.S. 32 (1991) 17 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91

arties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Iambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the i