📧 Communication

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.