57 results for "court deposition subpoena"
Page 1 of 3
DOJ-OGR-00002564.jpg
...All twelve depositions
were taken “pursuant to a court-approved stipulation to the effect that the depositions should be
treated as confidential and used solely by the parties for prosecution or defense of the action.” Jd.
at 292. Without seeking to intervene, and without serving a subpoena or warrant, the...
DOJ-OGR-00004792.jpg
...In the face of these straightforward precedents, Maxwell relies primarily on a single
district court case decided the year before the Second Circuit’s decision in Andover that quashed
a subpoena for deposition testimony covered by a civil protective order. See Dkt. No. 140, at
16-17 (citing United States...
DOJ-OGR-00003056.jpg
Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 122 of 239
The defendant asks the Court for a drastic remedy, namely suppression of a// evidence the
Government obtained pursuant to the subpoena, as well as the dismissal of Counts Five and Six.
In so doing...
DOJ-OGR-00002353.jpg
...obtained from a grand
jury subpoena it issued to I and to dismiss Counts Five and Six, which
are the fruits of that unlawful subpoena.
INTRODUCTION AND SUMMARY OF THE ARGUMENT
Counts Five and Six allege that Maxwell committed perjury during two civil depositions
conducted by Boies Schiller in a...
DOJ-OGR-00011197.jpg
...Bovino was served with a subpoena on November 30, 2021. Exhibits 1 & 2. The
subpoena was issued by the Clerk of this Court. Ms. Bovino has failed to comply with this
Court’s subpoena and order and is unwilling to testify as the subpoena commands. Testimony by
deposition is not...
DOJ-OGR-00002568.jpg
...Oshatz, in which this Court quashed a government
subpoena issued to a court reporter for a transcript of a deposition offered by the defendant in a
civil proceeding. 700 F. Supp. 696, 697 (S.D.N.Y. 1988). Oshatz (who had been indicted at the
time of his deposition) was...
DOJ-OGR-00011204.jpg
...person by subpoena” under the statute. § 3144.
9. And because the trial is ongoing, and because Ms. Bovino is not responding to our
attempts to contact her, her testimony “can[not] adequately be secured by
deposition.” § 3144.
10. Accordingly, under 28 U.S.C. § 3144, this Court can order Ms...
DOJ-OGR-00003556.jpg
Case tabave02secehAtP Duamuneitleris iti Wiese Papye dictebl
JISTRICT COURT
CT OF NEW YORK
UFFRE
Plaintiff,
Case No.:
-against- 15—-ov—-0 743 3-BWS
SLAINE MAXWELL,
Defendants.
io te ON F
Videotaped deposition of GHISLA
MAXWELL, taken pursuant to subpoena, was
held at the law offices of BOIES
SCHILLER & FLEXNER...
DOJ-OGR-00003790.jpg
...The district court declined to afford Ms.
Maxwell the requested relief. Ex. B.
The day before Maxwell’s April 2016 deposition, however, Judge Sweet ordered that
“Tajny materials that [Giuffre] has with respect to any criminal investigations will be turned over
[by Giuffre] except for any statements made by [Giuffre...
DOJ-OGR-00004154.jpg
...At a minimum, the government
had to have asked Boies Schiller about the size of the file and issues related to privilege to
determine if Boies Schiller would contest the subpoena or notify either the civil court or
Maxwell when the subpoena was issued and responsive documents produced. In fact...
DOJ-OGR-00008283.jpg
Case 1:20-cr-00330-PAE Document 533-2 Filed 12/09/21 Page 2 of 19
JISTRICT COURT
CT OF NEW YORK
UFFRE
Plaintiff,
Case No.:
-against- 15—-ov—-0 743 3-BWS
SLAINE MAXWELL,
Defendants.
io te ON F
Videotaped deposition of GHISLA
MAXWELL, taken pursuant to subpoena...
DOJ-OGR-00003063.jpg
...The court found that the subpoenas for the deposition
transcript were “unenforceable” because the “government has not argued that the protective order
was improvidently granted or that there are some extraordinary circumstances or compelling need,
in view of the holding in Martindell.”* Id. at 701. The court found that the...
DOJ-OGR-00004930.jpg
...See
In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221, 1225 (2d Cir.
1991) (“The proper procedure ... is . . . to subpoena the deposition transcripts for use in a
pending proceeding such as a grand jury investigation or trial, in which the issue could be raised...
DOJ-OGR-00004795.jpg
...Maxwell claims that she did not expect the Government to be able to obtain her
deposition testimony, and that if she knew it would, she never would have testified. If Maxwell
subjectively harbored this belief, it was nonetheless unreasonable. See Smith, 442 U.S. at 743.
The Court further notes...
DOJ-OGR-00003600.jpg
...Confidential
‘D STATES DISTRICT COURT
PRN DISTRICT OF NEW YORK
Se Aa ae ase a PF
N . UFFRE,
Plaintiff,
Case No.:
-against- 15-cv-07433-RWS
SLAINE MAXWELL,
Defendant.
* xX CONE ENTIAL**
Continued Videotaped Deposition of
GHISLAINE MAXWELL, the Defendant herein,
taken pursuant to subpoena, was held at
the law...
DOJ-OGR-00003548.jpg
...In the first instance, unlike in Subpoena Duces Tecum, the posture
of the Application does not involve a motion to quash. Of course, should this Court permit Boies
Schiller to respond, Boies Schiller would have the right to move to quash—including, for example,
if a grand jury subpoena made...
DOJ-OGR-00003554.jpg
...In the first instance, unlike in Subpoena Duces Tecum, the posture
of the Application does not involve a motion to quash. Of course, should this Court permit Boies
Schiller to respond, Boies Schiller would have the right to move to quash—including, for example,
if a grand jury subpoena made...
DOJ-OGR-00002812.jpg
...I write on behalf of Boies Schiller Flexner LLP (“BSF”) with respect to Defendant
Ghislaine Maxwell’s motion for an order authorizing a subpoena on BSF pursuant to Rule 17(c)(3)
of the Federal Rules of Criminal Procedure (the “Subpoena”) and the Court’s March 12, 2021,
Sealed and...
DOJ-OGR-00002877.jpg
...I write on behalf of Boies Schiller Flexner LLP (“BSF”) with respect to Defendant
Ghislaine Maxwell’s motion for an order authorizing a subpoena on BSF pursuant to Rule 17(c)(3)
of the Federal Rules of Criminal Procedure (the “Subpoena”) and the Court’s March 12, 2021,
Sealed and...
DOJ-OGR-00001764.jpg
...the use of a non-ex parte subpoena with an opportunity for the aggrieved party to
move to quash. Similar cases in this district demonstrate the “non-standard” nature of the
government’s conduct regarding these subpoenas. For example, Judge Koeltl observed when
considering whether to release a single deposition...
DOJ-OGR-00004789.jpg
...Much of what the Government obtained through its subpoena,
including the bulk of the deposition transcripts Maxwell now seeks to suppress, have since been
unsealed by court order in the civil case. See Giuffre, No. 15-cv-7433, Dkt. Nos. 1137, 1212.
Il. Discussion
Maxwell objects both to the Government...
DOJ-OGR-00003552.jpg
...Here, there is no such deficiency in the form of request
nor a challenge by the recipient of the subpoena. Indeed, in Chemical Bank, which cited
Martindell, the district court opined that had the Government obtained judicial relief to issue an
such as documents and depositions are not likely to...
DOJ-OGR-00003546.jpg
...The Court held that the Government was not entitled to the materials unless it
could show either that the protective order was improvidently granted or some extraordinary
circumstance or compelling need for the material; see also In re Grand Jury Subpoena Duces
Tecum Dated Apr. 19, 1991 (“Subpoena Duces Tecum...
DOJ-OGR-00003783.jpg
...In Martindell, the Second Circuit held that “the proper procedure” to obtain
confidential material under a Protective Order, “as the Government should know, was either to
subpoena the deposition transcripts for use in a pending proceeding such as a grand jury
investigation or trial, in which the issue could be...
DOJ-OGR-00002368.jpg
...CONCLUSION
For these reasons, this Court should: (1) suppress all evidence the government obtained
from QM and any other evidence derived therefrom; or (2) suppress the April and July
2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six.
Maxwell requests an evidentiary hearing on this...
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