This document is a legal motion filed on February 4, 2021, by Ghislaine Maxwell's defense team seeking to suppress evidence obtained via a grand jury subpoena and to dismiss perjury charges (Counts Five and Six). The defense argues that the government unlawfully circumvented a Protective Order from the civil case *Giuffre v. Maxwell* by issuing a subpoena and proceeding *ex parte* to prevent the accuracy of their representations from being contested. The recipient of the subpoena and specific details of the government's arguments are heavily redacted.
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Moving to suppress evidence obtained via grand jury subpoena and dismiss Counts Five and Six.
|
| Giuffre | Plaintiff (Civil Case) |
Named in case citation 'Giuffre v. Maxwell'; client represented by Boies Schiller.
|
| Name | Type | Context |
|---|---|---|
| Boies Schiller |
Conducted civil depositions in the defamation action against Maxwell.
|
|
| Government |
Issued the subpoena being contested; accused of proceeding ex parte to avoid contestation.
|
|
| S.D.N.Y |
Southern District of New York, where the civil case was filed.
|
|
| DOJ |
Implied by Bates stamp prefix 'DOJ-OGR'.
|
| Location | Context |
|---|---|
|
Southern District of New York (Jurisdiction)
|
"Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to [REDACTED] and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena."Source
"Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller..."Source
"A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material... with anyone else, including with the government and law enforcement."Source
"By proceeding ex parte, the government ensured that no one before the court would be able to contest the accuracy of its representations in support of its application."Source
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