Epstein Secrets

that "the defense will receive notice of any co-conspirator statements that the Government may seek to introduce through witness statements" in its Jencks Act production. (Gov't Opp. at 192, Dkt. No. 204). The Court denied the motion, explaining that the Court lacked the power to order pretrial discl

eral Evidence § 702.02 [2] (2d ed. 2006)). Finally, even if the expert testimony is reliable, it must also be relevant. See, e.g., United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. May 13, 2021). In this context, the testimony must "concern matters that the average juror i

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00096241 August 1, 2019 Page 11

e general nature of certain portions of the Indictment does "not advise [Mr. Epstein] of the specific acts of which he is accused." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990). See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154

and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness's testimony to allow adequate time to prepare for cross- examination. These representations are sufficie

ainst him if this is 174 EFTA00103199 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q

and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness's testimony to allow adequate time to prepare forcross- examination. These representations are sufficien

nst him if this is 174 EFTA00100141 necessary to the preparation of his defense, and to avo id prejud icial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q

and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness's testimony to allow adequate time to prepare for cross- examination. These representations are sufficie

ainst him if this is 174 EFTA00077806 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q

and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness's testimony to allow adequate time to prepare for cross- examination. These representations are sufficie

ainst him if this is 174 EFTA00039621 necessary to the preparation of his defense, and to avoid prejudicial surprise at trial." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir.2010) (emphasis added) (internal q

and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness's testimony to allow adequate time to prepare for cross- examination. These representations are sufficie

h the defendant committed the crime charged, or a preview of the Government's evidence or legal theories." Mitlof, 165 F. Supp. 2d at 569; see also Torres, 901 F.2d at 234 ("Acquisition of evidentiary detail is not the function of the bill of particulars.' (quoting Hemphill v. United States, 392 F.2d 4

e general nature of certain portions of the Indictment does "not advise [Mr. Epstein] of the specific acts of which he is accused." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990). See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154

se us promptly whether the government will be producing Brady material immediately even if it is contained in what might otherwise be considered as Jencks material, or whether you take the position that you arc not obligated to produce such material at this time. EFTA00016145 --- PAGE BREAK --- Aug

F. Supp. 2d 368, 384 (S.D.N.Y. 2010) (same). "Acquisition of evidentiary details is not the function of the bill of particulars." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir. 2010) (quotations marks and citat

ernment's letter dated October 28, 2020, with regard to your many requests for information that fall within the scope of the Government's Giglio and Jencks Act obligations, we intend to produce all such material in advance of trial and remain available to confer generally regarding a mutual schedule fo