Epstein Secrets

ter held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcr

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

ter held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcr

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

ter held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcr

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

es named Matthew Russell Brown, 66, as the suspect accused of murdering Robert Miller inside his south Minneapolis apartment on July 17, 1984, when Brown would have been 27 years old. The article added that MPD said in a press release that its investigators, along with FBI agents, interviewed Brown la

have been made, including requiring multiple people to sign off on wire transfers. Former U.S. Prison Employee to Admit to Accepting Payments From Rajaratnam Reuters (07/25, Raymond) reported that a former employee of a federal prison in Massachusetts has agreed to plead guilty to secretly accepting thou

t be used to obtain documents that would be excluded on hearsay grounds or would otherwise be "inadmissible as evidence at trial." United States v. Brown, No. 95 CR. 168 (AGS), 1995 WL 387698, at •10 (S.D.N.Y. June 30, 1995) (Schwartz, 1). Documents bearing on a witness's decision to "cooperate with

fs.' PRI Opp'n, at 27 (citing United States v. Yudung Zhu, No. 13 CR. 761, 2014 WL 5366107 (S.D.N.Y. Oct. 14, 2014) (Marrero, J.); United States v. Rajaratnam, 753 F. Supp. 2d 317 (S.D.N.Y. 2011) (I lolwell, J.); and United Stales v. McClure, No. CRIM.A. 10-028, 2010 WL 3523030 (E.D. La. Sept. 1, 2010)).)

18 EFTA00086659 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

.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Ck. 2013) 18 United States v. Valentine, 820 F.2d 565 (2d Cir. 1987) 16 Young v. United States, 481 U.S. 787 (1987) 16 ii

ter held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcr

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

ter held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcr

d Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inher

closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan

ndment right of the accused to a fair trial. .. and the defendant's ... privacy interests.") (internal quotations omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010)); Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D. Conn. A

lear, and that court has followed it steadfastly since. See, e.g., United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States v. Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United Sta

the other hand, the Court must balance these interests against the harm to the Government from restricting its proof at trial. See United States v. Rajaratnam, No. 09-cr-1184 (RJH), 2010 WL 2788168, at *1 (S.D.N.Y. Jul. 13, 2010). In her previous motions, Maxwell argued that the Mann Act counts in the ind