Epstein Secrets

43, 247 United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), aff'd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 108

ries insufficient; "no one suggests that every delay- caused detriment to a defendant's case should abort a criminal prosecution"); United States v. Snyder, 668 F.2d 686, 689 (2d Cir. 1982) (death of a defense witness three years before indictment insufficient prejudice); United States v. lannelli, 461

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

243, 247 United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 108

ries insufficient; "no one suggests that every delay- caused detriment to a defendant's case should abort a criminal prosecution"); United States v. Snyder, 668 F.2d 686, 689 (2d Cir. 1982) (death of a defense witness three years before indictment insufficient prejudice); United States v. lannelli, 461

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

243, 247 United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 108

ries insufficient; "no one suggests that every delay- caused detriment to a defendant's case should abort a criminal prosecution"); United States v. Snyder, 668 F.2d 686, 689 (2d Cir. 1982) (death of a defense witness three years before indictment insufficient prejudice); United States v. lannelli, 461

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

Smith, 985 F. Supp. 2d 547 (S.D.N.Y. 2014) United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007) United States v. Snyder, 159, 160, 167 162 139 668 F.2d 686 (2d Cir. 1982) 44, 53 United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) 203 United States v.

ries insufficient; "no one suggests that every delay- caused detriment to a defendant's case should abort a criminal prosecution"); United States v. Snyder, 668 F.2d 686, 689 (2d Cir. 1982) (death of a defense witness three years before indictment insufficient prejudice); United States v. lannelli, 461

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

243, 247 United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 108

ries insufficient; "no one suggests that every delay- caused detriment to a defendant's case should abort a criminal prosecution"); United States v. Snyder, 668 F.2d 686, 689 (2d Cir. 1982) (death of a defense witness three years before indictment insufficient prejudice); United States v. lannelli, 461

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