Epstein Secrets

0203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

ON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Phone: Bobbi C. Stemheim Law Off

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

uca Laura A. Mennin • er Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of

as standing. 1 B. There is no good faith. 5 C. The government's inevitable discovery doctrine fails. 5 II. The Government's violation of Manindell requires suppression. 7 III. The Government's violation of the Fifth Amendment requires suppression 10 IV. The Court should hold an evidentiary

MORGAN & FOREMAN P.C. Denver, CO 80203 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobb

overnment there should have either moved to intervene or issued a subpoena to obtain th . For one thing, the Fourth Amendment was not at issue in Manindell, so the Court had no occasion to decide whether a warrant might have been required. For another, Martindell does not speak to what showing would hav

s and that require a subpoena duces tenon of such records to be supported by probable cause). Finally, of course, the government didn't comply with Manindell because it never gave Maxwell notice and an opportunity to quash the subpoena and to challenge the government's misrepresentations through the adver