EFTA00015303.pdf

1.16 MB
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Extraction Summary

8
People
5
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal memorandum / motion to suppress and dismiss
File Size: 1.16 MB
Summary

This document is a legal memorandum filed on January 25, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The motion seeks to suppress evidence obtained via a grand jury subpoena issued to a third party (name redacted) and to dismiss Counts Five and Six of the indictment. The defense argues that the subpoena violated the Fourth Amendment due to overbreadth and lack of a warrant, violated the 'Martindell' doctrine regarding the sanctity of protective orders in civil litigation, and infringed upon Maxwell's Fifth Amendment rights against self-incrimination regarding her 2016 civil deposition testimony.

People (8)

Name Role Context
Ghislaine Maxwell Defendant
Seeking to suppress evidence and dismiss counts 5 and 6.
Jeffrey S. Pagliuca Defense Attorney
Attorney for Maxwell, Haddon, Morgan & Foreman P.C.
Laura A. Menninger Defense Attorney
Attorney for Maxwell, Haddon, Morgan & Foreman P.C.
Mark S. Cohen Defense Attorney
Attorney for Maxwell, Cohen & Gresser LLP.
Christian R. Everdell Defense Attorney
Attorney for Maxwell, Cohen & Gresser LLP.
Bobbi C. Sternheim Defense Attorney
Attorney for Maxwell, Law Offices of Bobbi C. Sternheim.
Alison J. Nathan (AJN) Judge
Presiding Judge indicated in the case caption (20 Cr. 330 (AJN)).
Judge Sweet Judge
Judge in the civil defamation action who ordered the return/destruction of confidential information.

Organizations (5)

Name Type Context
United States District Court Southern District of New York
Venue for the criminal case.
United States of America
Prosecuting party.
Haddon, Morgan & Foreman P.C.
Defense counsel firm (Denver).
Cohen & Gresser LLP
Defense counsel firm (New York).
U.S. Attorney's Office, SDNY
Recipient of service.

Timeline (2 events)

2016
Civil defamation action settlement (settled before trial).
Unknown
Ghislaine Maxwell Plaintiffs (implied)
2021-01-25
Filing of Memorandum in Support of Motion to Suppress and Dismiss.
SDNY Court
Ghislaine Maxwell Defense Attorneys

Locations (2)

Location Context
Location of the court and several legal offices.
Location of Haddon, Morgan & Foreman P.C.

Relationships (2)

Ghislaine Maxwell Litigation/Custodial [Redacted Entity]
Maxwell's files/transcripts were in the possession of this entity, and she sued them (or vice versa) in civil court.
Ghislaine Maxwell Judicial Judge Sweet
Judge Sweet presided over the civil case and ordered the return/destruction of confidential information.

Key Quotes (4)

"The subpoena violated the Fourth Amendment because it was overbroad and because it effected a warrantless search and seizure of material in which Maxwell had a reasonable expectation of privacy."
Source
EFTA00015303.pdf
Quote #1
"The government may not . . . simply by picking up the telephone or writing a letter to the court . . . insinuate itself into a private civil lawsuit between others."
Source
EFTA00015303.pdf
Quote #2
"Maxwell had a legitimate expectation of privacy in her [redacted] because she reasonably sought to preserve them as private."
Source
EFTA00015303.pdf
Quote #3
"The subpoena to [redacted] was unconstitutionally overbroad, and this Court should suppress all evidence produced in response."
Source
EFTA00015303.pdf
Quote #4

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