mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003784.json

{
  "document_metadata": {
    "page_number": "10",
    "document_number": "212",
    "date": "04/16/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 212 Filed 04/16/21 Page 10 of 20\n\nB. There is no good faith.\nThe rebuttal to government's good faith claim is simple: There can be no good faith when the government willfully and intentionally misleads the court into authorizing its search.\nAs the United States Supreme Court held in United States v. Leon, Suppression . . . remains an appropriate remedy if the magistrate or judge in issuing a warrant was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard of the truth.\n468 U.S. 897, 923 (1984).\nHere, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government acts in objective bad faith.\nC. The government's inevitable discovery doctrine fails.\nThere are several reasons the government's inevitable discovery argument fails.\nFirst, the inevitable discovery doctrine is an exception to the Fourth Amendment's exclusionary rule. United States v. Stokes, 733 F.3d 438, 442–43 (2d Cir. 2013) (reversing district court's denial of motion to suppress, which was based on \"the inevitable discovery doctrine, an exception to the Fourth Amendment's exclusionary rule\"). The doctrine has no applicability when a court exercises its inherent or supervisory authority to suppress evidence obtained through deliberate government misconduct. The exercise of that authority is meant to vindicate the dignity of the Court and to deter improper governmental conduct. See United States v. Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980) (\"The need for deterrence of illegal conduct is, in one sense, greater here than [elsewhere], for [the government's] offense was committed within the sanctity of the court itself.\")\n\n5\nDOJ-OGR-00003784",
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      "content": "Case 1:20-cr-00330-PAE Document 212 Filed 04/16/21 Page 10 of 20",
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    {
      "type": "printed",
      "content": "B. There is no good faith.\nThe rebuttal to government's good faith claim is simple: There can be no good faith when the government willfully and intentionally misleads the court into authorizing its search.\nAs the United States Supreme Court held in United States v. Leon, Suppression . . . remains an appropriate remedy if the magistrate or judge in issuing a warrant was misled by information in an affidavit that the affiant knew was false or would have known was false except for his reckless disregard of the truth.\n468 U.S. 897, 923 (1984).\nHere, as explained in Maxwell's due process motion to suppress and the reply in support thereof, the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller. The good faith doctrine does not apply when the government acts in objective bad faith.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. The government's inevitable discovery doctrine fails.\nThere are several reasons the government's inevitable discovery argument fails.\nFirst, the inevitable discovery doctrine is an exception to the Fourth Amendment's exclusionary rule. United States v. Stokes, 733 F.3d 438, 442–43 (2d Cir. 2013) (reversing district court's denial of motion to suppress, which was based on \"the inevitable discovery doctrine, an exception to the Fourth Amendment's exclusionary rule\"). The doctrine has no applicability when a court exercises its inherent or supervisory authority to suppress evidence obtained through deliberate government misconduct. The exercise of that authority is meant to vindicate the dignity of the Court and to deter improper governmental conduct. See United States v. Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980) (\"The need for deterrence of illegal conduct is, in one sense, greater here than [elsewhere], for [the government's] offense was committed within the sanctity of the court itself.\")",
      "position": "middle"
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    {
      "type": "printed",
      "content": "5",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003784",
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "McMahon"
    ],
    "organizations": [
      "United States Supreme Court",
      "Boies Schiller"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "1984",
      "2013",
      "1980"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212",
      "468 U.S. 897",
      "733 F.3d 438",
      "630 F.2d 1207",
      "DOJ-OGR-00003784"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a formal tone and legal language. There are no visible redactions or damage to the document."
}