{
  "document_metadata": {
    "page_number": "103",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 103 of 239\n\ncommitted perjury.\" According to two anonymous sources, \"a second meeting occurred.\"\nHowever, the Article cites another anonymous source as \"insist[ing] [a second meeting] never\nhappened.\"\n\nB. The Defendant's Suppression Motion Should Be Denied\n\nMaxwell seeks suppression of the evidence the Government obtained via a judicially\nauthorized subpoena to Boies Schiller under Martindell, the Fourth Amendment, Fifth\nAmendment, the Due Process clause, and the Court's inherent authority. However, Maxwell's\nmotion turns on erroneous facts, runs afoul of controlling law, and should be denied.\n\n1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks\n\nMaxwell argues that the Government \"circumvented\" the Second Circuit's decision in\nMartindell and \"violated Maxwell's rights,\" which requires suppression of the evidence the\nGovernment obtained from the subpoena. (Def. Mot. 11 at 11-12). Even assuming that to be\ntrue—which, of course, as detailed above and herein, it is not—there is no basis in law to suppress\nevidence as a result of a Martindell violation, and Maxwell cites none in support of her claim.\nSetting that fatal flaw aside, however, her claim is wrong on both the facts and the law. The\nGovernment issued a valid grand jury subpoena for the materials, applied for judicial authorization\nto modify the protective order to permit compliance with the subpoena, and a district court judge,\nwho evaluated the Government's application under Martindell, properly exercised her discretion\nin modifying the protective order. Only after receiving that court order did the Government obtain\nany protected materials from Boies Schiller. Maxwell's motion should be denied.\n\na. Applicable Law\n\n\"[T]here is no question that a Rule 26(c) protective order is subject to modification,\" and\na decision to modify such an order is \"committed to the sound discretion of the trial court.\" In re\n\n76\nDOJ-OGR-00003037",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 103 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "committed perjury.\" According to two anonymous sources, \"a second meeting occurred.\"\nHowever, the Article cites another anonymous source as \"insist[ing] [a second meeting] never\nhappened.\"\n\nB. The Defendant's Suppression Motion Should Be Denied\n\nMaxwell seeks suppression of the evidence the Government obtained via a judicially\nauthorized subpoena to Boies Schiller under Martindell, the Fourth Amendment, Fifth\nAmendment, the Due Process clause, and the Court's inherent authority. However, Maxwell's\nmotion turns on erroneous facts, runs afoul of controlling law, and should be denied.\n\n1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks\n\nMaxwell argues that the Government \"circumvented\" the Second Circuit's decision in\nMartindell and \"violated Maxwell's rights,\" which requires suppression of the evidence the\nGovernment obtained from the subpoena. (Def. Mot. 11 at 11-12). Even assuming that to be\ntrue—which, of course, as detailed above and herein, it is not—there is no basis in law to suppress\nevidence as a result of a Martindell violation, and Maxwell cites none in support of her claim.\nSetting that fatal flaw aside, however, her claim is wrong on both the facts and the law. The\nGovernment issued a valid grand jury subpoena for the materials, applied for judicial authorization\nto modify the protective order to permit compliance with the subpoena, and a district court judge,\nwho evaluated the Government's application under Martindell, properly exercised her discretion\nin modifying the protective order. Only after receiving that court order did the Government obtain\nany protected materials from Boies Schiller. Maxwell's motion should be denied.\n\na. Applicable Law\n\n\"[T]here is no question that a Rule 26(c) protective order is subject to modification,\" and\na decision to modify such an order is \"committed to the sound discretion of the trial court.\" In re",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "76",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003037",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Boies Schiller",
      "Second Circuit",
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Def. Mot. 11 at 11-12",
      "Rule 26(c)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case against Maxwell. The text discusses the defendant's suppression motion and the government's response. The document is well-formatted and free of significant damage or redactions."
}