Epstein Secrets

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

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

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

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

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

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

mited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed

ges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in

atively limited, due to the confidential nature" of the litigation. (Id. at 2 n.1). The Government also submitted that the court need not employ the Manindell balancing test to evaluate the Government's ability to obtain access to materials covered by a protective order because (1) the Martindell balancin

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"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu

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"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

fy Rule 26(c) protective orders that precluded full compliance with those subpoenas. While the Government argued that the court need not employ the Manindell balancing test for several reasons, it also made arguments under Martindell in the alternative. Ultimately, both Chief Judge McMahon and Judge Netbu