Epstein Secrets

d States v. Amato, 15 F.3d 230 (2d Cir. 1994) 209 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 222 United States v. Anderson, 747 F.3d 51 (2d Cir. 2014) 212 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 162 United States v. Annabi, 10 Cr. 07 (CM) 286 ix

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

d States v. Amato, 15 F.3d 230 (2d Cir. 1994) 209 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 222 United States v. Anderson, 747 F.3d 51 (2d Cir. 2014) 212 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 162 United States v. Annabi, 10 Cr. 07 (CM) 286 ix E

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

d States v. Amato, 15 F.3d 230 (2d Cir. 1994) 209 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 222 United States v. Anderson, 747 F.3d 51 (2d Cir. 2014) 212 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 162 United States v. Annabi, 10 Cr. 07 (CM) 286 ix E

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

d States v. Amato, 15 F.3d 230 (2d Cir. 1994) 140 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 148 United States v. Anderson, 747 F.3d 51 (2d Cir. 2014) 142 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 110 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985

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

d States v. Amato, 15 F.3d 230 (2d Cir. 1994) 209 United States v. An Antique Platter of Gold, 184 F.3d 131 (2d Cir. 1999) 222 United States v. Anderson, 747 F.3d 51 (2d Cir. 2014) 212 United States v. Anderson, 772 F.3d 969 (2d Cir. 2014) 162 United States v. Annabi, 10 Cr. 07 (CM) 286 ix

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

statements are admissible as proof of a defendant's consciousness of guilt (see Gov't Opp. at 142-43, Dkt. No. 204 (citing, e.g., United States v. Anderson, 747 F.3d 51, 60 (2d Cir. 2014)), the Government does not intend—and so will agree—not to offer this information as part of its case-in-chief, unles

(Id.) On June 2, 2021, the Court adopted the "Government's proposal" and set a deadline of October 11, 2021, for the "disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and 56 EFTA00088858 notice, co-conspirator statements, and Government witness list," as well as the "Defendant's

ly not only to references to unitidicted co-conspirators in indictments and factual proffers, but also to motion papers. See, e.g.. United States v. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving papers on the conflict of interest issue, the court c

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio v. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law th

pply not only to references to unindicted co-conspirators in indictments and factual proffers, but also to motion papers. See, e.g.. United States'. Anderson, 55 F. Supp. 2d 1163, 1168 (D. Kan. 1999) ("After carefully reviewing the government's moving papers on the conflict of interest issue, the court c

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio i United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the