(USANYS)" •
Summary
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.
Persons Referenced (6)
“...obbi C Sternheim [email protected] [email protected] [email protected] Christian R. Everdell ceverdell@cohengressercom autodocket@cohengressercom Mark Stewart Cohen mcoh...”
JEFFREY S. PAGLIUCA“...mailed to: David Boles, II [email protected] NYC Managing [email protected] Jeffrey S. Pagliuca [email protected] [email protected] Laura A. Menninger Imenning@hmflaw....”
The Defendant“...day's date through November 29, 2021, outweigh the interests of the public and the Defendant in a speedy trial, because this time is necessary to permit the defense to con...”
United StatesGhislaine Maxwell“...ber: 1:20-cr-00330-AJN Filer: Document Number:277 Docket Text: ORDER as to Ghislaine Maxwell: The Court has considered the parties' proposals regarding the commencement of...”
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EFTA DisclosureRelated Documents (6)
Cc: Jeff Pagliuca cipae,huca(tclunllaw.com>, Laura Memunger Klmennme,er(alimflaw.corn.?.
Fromi To: Cc: Jeff Pagliuca cipae,huca(tclunllaw.com>, Laura Memunger Klmennme,er(alimflaw.corn.?. bestentheim_mae.com <besternheirn(iipnac.com> Subject: [EXTERNAL] FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order Date: Fri, 19 Nov 2021 17:41:14 +0000 Counsel — The defense has no redactions to propose. Thanks, Chris From: [email protected] <[email protected]> Sent: Friday, November 19, 2021 11:21 AM To: [email protected] Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order 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••• There is no charge for viewing opinions. U.S. District Court Southern District of New York Notice of Electronic Filing The following transaction was entered on 11/19/2021 at 11:21 AM EST and filed on 11/19/2021 Case Name: USA v. Maxwell Case Number: 1:20-cr-0033
FronIIIIIIIIIIIII(USANYS)"
FronIIIIIIIIIIIII(USANYS)" To (NY) (FBI)" Subject: [EXTERNAL EMAIL] - FW: Activity in Case 1:20-er-00330-AIN USA v. Maxwell Remark Date: Fri, 01 Apr 2022 19:01:54 +0000 Importance: Normal From: NYSD ECF [email protected]<NYSD ECF [email protected]> Sent: Friday, April 1, 2022 1:58 PM To: [email protected] Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Remark 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 later charges, download a copy of each document during this first viewing. However, if the referenced docum
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
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 (MN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE 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. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Attorneys for Ghislaine Maxwell EFTA00077571 Table of Contents Table of Contents Table of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's De
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
From: Christian Everdell
From: Christian Everdell To: (USANYS)" Subject: [EXTERNAL] FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion Date: Mon, 22 Nov 2021 19:40:14 +0000 We now file our response to the birth certificate motion, right? From: [email protected] <[email protected]> Sent: Monday, November 22, 2021 2:03 PM To: [email protected] Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion 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 later charges, download a copy of each document duri
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