Epstein Secrets

ocument 269 Filed 05/04/21 Page 7 of 9 Page 7 individual "is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct

al without such production,' and that `the application is made in good faith and is not intended as a general "fishing expedition. United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700), abrogated on other grounds as recognized by United States v. Chambers, 751 F.

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

ly three to four weeks before trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KBF). As the Government has noted for some time now, the Government intends to match or even go above and beyond that practice in this c

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

fore trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Levin, 15 Cr. 101 (KBF); Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KBF). As the Government has noted for some time now, the Government intends to match or even go above and beyond that practice in this c

al without such production,' and that `the application is made in good faith and is not intended as a general "fishing expedition. United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700), abrogated on other grounds as recognized by United States v. Chambers, 751 F.

ocument 269 Filed 05/04/21 Page 7 of 9 Page 7 individual "is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct