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2008 WL 161146 (E.D. Pa. Jan. 16, 2008) 216 United States v. Brown, No. 99-1230, 2002 WL 34244994, at (2d Cir. Apr. 26, 2002) 6 United States v. Bruno, 159 F. Supp. 3d 311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ),
harged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
2008 WL 161146 (E.D. Pa. Jan. 16, 2008) 216 United States v. Brown, No. 99-1230, 2002 WL 34244994, at (2d Cir. Apr. 26, 2002) 6 United States v. Bruno, 159 F. Supp. 3d 311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ),
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
2008 WL 161146 (E.D. Pa. Jan. 16, 2008) 216 United States v. Brown, No. 99-1230, 2002 WL 34244994, at (2d Cir. Apr. 26, 2002) 6 United States v. Bruno, 159 F. Supp. 3d 311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ),
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
WL 161146 (E.D. Pa. Jan. 16, 2008) 144 United States v. Brown, No. 99-1230, 2002 WL 34244994, at (2d Cir. Apr. 26, 2002) 5, 19 United States v. Bruno, 159 F. Supp. 3d 311 (E.D.N.Y. 2016) 5 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 156 United States v. Burke, No. 09 Cr. 135 (SJ),
ismissal of an indictment filed within the statute of limitations must establish that the Government acted intentionally, scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The de
not been dismissed on other grounds." (Def. Mot. 7 at 1). As noted above, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial, consistent with whatever schedule the parties agree upon or this Court sets. The Court should re
2008 WL 161146 (E.D. Pa. Jan. 16, 2008) 216 United States v. Brown, No. 99-1230, 2002 WL 34244994, at (2d Cir. Apr. 26, 2002) 6 United States v. Bruno, 159 F. Supp. 3d 311 (E.D.N.Y. 2016) 7 United States v. Bunn, 154 F. App'x 227 (2d Cir. 2005) 237 United States v. Burke, No. 09 Cr. 135 (SJ),
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. The defe
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
Entities connected to both Bruno and Giglio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Southern District of New York
ORGANIZATIONthe Southern District
LOCATIONEmmy Taylor
PERSON
Reid Weingarten
PERSONCollins
PERSONAnnabi
PERSON
Michael Cohen
PERSON
George Mitchell
PERSONSalameh
PERSON
Scarlett Johansson
PERSONBortnovsky
PERSONMartin Weinberg
PERSON
Audrey Strauss
PERSON
David Boies
PERSON