Epstein Secrets

2 United States v. Gibson, 175 F. Supp. 2d 532 (S.D.N.Y. 2001) 268 United States v. Gilbert, 266 F.3d 1180 (9th Cir. 2001) 62 United States v. Gillette, 383 F.2d 843 (2d Cir. 1967) 165 United States v. Gonzalez, No. 00 Cr. 447,2000 WL 1721171 85 United States v. Gottfried, 165 F.2d 360 (2d C

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

2 United States v. Gibson, 175 F. Supp. 2d 532 (S.D.N.Y. 2001) 268 United States v. Gilbert, 266 F.3d 1180 (9th Cir. 2001) 62 United States v. Gillette, 383 F.2d 843 (2d Cir. 1967) 165 United States v. Gonzalez, No. 00 Cr. 447, 2000 WL 1721171 85 United States v. Gottfried, 165 F.2d 360 (2d Ci

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

2 United States v. Gibson, 175 F. Supp. 2d 532 (S.D.N.Y. 2001) 268 United States v. Gilbert, 266 F.3d 1180 (9th Cir. 2001) 62 United States v. Gillette, 383 F.2d 843 (2d Cir. 1967) 165 United States v. Gonzalez, No. 00 Cr. 447, 2000 WL 1721171 85 United States v. Gottfried, 165 F.2d 360 (2d Ci

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

1 United States v. Gibson, 175 F. Supp. 2d 532 (S.D.N.Y. 2001) 176 United States v. Gilbert, 266 F.3d 1180 (9th Cir. 2001) 43 United States v. Gillette, 383 F.2d 843 (2d Cir. 1967) 112 United States v. Gonzalez, No. 00 Cr. 447, 2000 WL 1721171 58 United States v. Gottfried, 165 F.2d 360 (2d Ci

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

2 United States v. Gibson, 175 F. Supp. 2d 532 (S.D.N.Y. 2001) 268 United States v. Gilbert, 266 F.3d 1180 (9th Cir. 2001) 62 United States v. Gillette, 383 F.2d 843 (2d Cir. 1967) 165 United States v. Gonzalez, No. 00 Cr. 447, 2000 WL 1721171 85 United States v. Gotyhed, 165 F.2d 360 (2d Cir.

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