5
Shared Docs
5
Same-Page
9 / 5
Mentions
explain this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which
ns," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the g
material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1
explain this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then co
ns," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the g
material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1
explain this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then co
ns," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the g
material is in the possession of a third- party, a defendant has standing to challenge a grand jury subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1
Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!I
ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury' (
the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government
ile, attorney typed notes, relevant pieces of grand jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #15, 16, 17, 18, 19, Past Employees, Misc. Witnesses Work product 6(e)
documents that "might allow them to protect those very rights." (lcl at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
Entities connected to both David Boies and Subpoena Duces Tecum

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Donald Trump
PERSON
United States
LOCATIONthe Southern District
LOCATION
Virginia Giuffre
PERSONJane Doe
PERSONSouthern District
LOCATIONLeon Black
PERSON
Bill Clinton
PERSONJeffrey Pagliuca
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Department of Justice
ORGANIZATION