EFTA00015303.pdf

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (MN)"

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL"

"Jeffrey S. Pagliuca Attorneys for Chislaine Maxwell"

"Laura A. Menninger Attorneys for Chislaine Maxwell"

"Mark S. Cohen Attorneys for Chislaine Maxwell"

"Christian R. Everdell Attorneys for Chislaine Maxwell"

"Bobbi C. Sternheim Attorneys for Chislaine Maxwell"

"government obtained from a grand jury subpoena it issued to"

"dismiss Counts Five and Six, which are the fruits of that unlawful subpoena"

"dismiss Counts Five and Six, which are the fruits of that unlawful subpoena"

"The subpoena to was unconstitutionally overbroad, and this Court should suppress all evidence produced in response."

"REDACTED-001 sued her, not the other way around."

"The government's subpoena to REDACTED-001 was an unconstitutional Fourth Amendment seizure."

"everything else she designated as Confidential under the Protective Order"

"Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger"

"Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger"

"dismiss Counts Five and Six"

"suppress the April and July 2016 depositions and all evidence derived therefrom"

"suppress the April and July 2016 depositions and all evidence derived therefrom"

"Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C."

"Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C."

"Attorneys for Chislaine Maxwell"

"Attorneys for Chislaine Maxwell"

"Attorneys for Chislaine Maxwell"

"Attorneys for Chislaine Maxwell"

"I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Memorandum of Ghislaine Maxwell... upon the following"

"Christian R. Everdell COHEN & GRESSER LLP"

"Laura A. Menninger HADDON, MORGAN & FOREMAN P.C."

"U.S. Attorney's Office SDNY New York, NY 10007"

"The government met with before it issued the subpoena, it knew what was in file"

"So overbroad was the subpoena that actually produced to the government"

"the parties settled the defamation action before trial, conclusively establishing the privacy of Maxwell's deposition testimony"

"refused to do so although ordered to do so by Judge Sweet"

"the case settled before trial, thereby confirming Maxwell's legitimate expectation that th would not be shared outside the attorneys working in the ca"

"government didn't comply with Martindell because it never gave Maxwell notice and an opportunity to quash the subpoena"

"Maxwell did not even know the government had until after she was indicted"

"The subpoena to contravenes this proscription because it literally compels production of Maxwell's incriminating testimony"

"suppress the April and July 2016 depositions and all evidence derived therefrom"

"suppress the April and July 2016 depositions and all evidence derived therefrom"

"the Protective Order, which prohibited from sharing them with third parties, including law enforcement"

"government trampled on Maxwell's Fifth Amendment privilege against self-incrimination"