336.pdf

Type

pdf

Source set

house-oversight-doj

Pages

10

Text status

Searchable text available

OCR confidence

0.9300541490884907

Original source

Extracted text

Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page1of10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, 20 Cr. 330 (AJN) Mi. GHISLAINE MAXWELL, Defendant. MS. MAXWELL’S SECOND EX PARTE AND IN CAMERA MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell DOJ-OGR-00005043 

Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page2of10 Defendant Ghislaine Maxwell makes this second ex parte and in camera motion for the Court to enter an Order authorizing her counsel to issue additional subpoenas under Federal Rule of Criminal Procedure 17(c). The legal and factual grounds for this second motion are largely identical to those set forth in Ms. Maxwell’s first ex parte and in camera motion (“First Motion”) for issuance of a subpoena to the law firm Boies, Schiller and Flexner LLP (“BSF”), filed with the Court on February 21, 2021, and Ms. Maxwell expressly incorporates that First Motion by reference. Because additional subpoenas are necessary for (a) her pending pre-trial motions, and (b) in order to examine certain physical pieces of evidence in advance of trial in order to adequately prepare for trial, she hereby sets forth additional facts and argument pursuant to United States v. Nixon, 418 U.S. 683, 699-700 (1974), to justify these additional subpoenas. As with her First Motion, she makes this motion ex parte for the “strong policy reasons in favor of an ex parte” process and because she is providing detail regarding her investigative and trial strategy to demonstrate compliance with the specificity, relevance, and admissibility …

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