Subject: FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter

EFTA00011418

Subject: [EXTERNAL EMAIL] - FW: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of

From: To: Subject: [EXTERNAL EMAIL] - FW: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of Case Assignment/Reassignment Date: Fri, 01 Apr 2022 17:23:23 +0000 Importance: Normal Also FYI. This is all we know right now, but will keep you updated. From: [email protected] <[email protected]> Sent: Friday, April 1, 2022 12:52 PM To: [email protected] Subject: Activity in Case 1:20-cr-00330-VSB USA v. Maxwell Notice of Case Assignment/Reassignment This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e- mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS••• Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid lat

EFTA00028106

EFTA00011452

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE FOURTH AMENDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Mennin • er Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00097649 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORITIES iii TABLE OF EXHIBITS Factual Background 1 Argument 1 I. The Government's violation of the Fourth Amendment requires suppression 1 A. Maxwell has 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

(USANYS)" •

From: To: (USANYS)" • (NY) (FBI) Cc: USANYS (USANYS)" (USANYS)" Subject: FW: Activity in Case 1:20-er-00330-AJN USA v. Maxwell Order to Continue - Interest of Justice Date: Tue, 11 May 2021 21:35:25 +0000 Attachments: 2021.05.11,_GM,_scheduling_orderpdf Mnd MO - From: [email protected] <[email protected]> Sent: Tuesday, May 11, 2021 4:58 PM To: [email protected] Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order to Continue - Interest of Justice This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e- mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users.