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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
Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELI
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
Case 1:20-cr-00330-AJN Document 269 Filed 05/04/21 Page 1 of 9 U.S. Department of Justice United States Attorney Southern District of New York The Si)WaJ. Mono Building One Saint Andrew 's Plaza New York New York 10007 May 4, 2021 BY ECF The Honorable Alison J. Nathan Unit
ts, their credibility and the foundations. if any. for claiming personal injury. Also. Mr. Epstein would have received, pursuant to either Brady or Jencks. material in the lbrm of prior inconsistent statements made by these women before they learned of any financial benefit that may be available to the
lelkowda I M L Iamicorri VIA FACSIMILE (305) 530-6444 I lonnrable It. Alexander Acosta United States Attorney United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami. Fl. 33132 I kar Alex: ANO ANN IA1M PAROVCRANO% Ciaoroup Cantor 153 Coal 53W Slowl New York. Now York 1002:
ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006001
ocket 09'27:2011 Page 12 of 12 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954)
ed that, when defense counsel elected to put his investigator on the witness stand at trial, he must turn over the investigator's report pursuant to Jencks, but defense counsel can redact the report to only disclose that portion of the report that relates to the investigator's testimony. 7 EFTA006570
ocket 09'27:2011 Page 12 of 12 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954)
Entities connected to both Jencks and Southern District

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONJack Goldberger
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Paul Cassell
PERSONLeon Black
PERSON
George W. Bush
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSON