Epstein Secrets

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.

ernment obtains the boots and makes them available for inspection by the defendant, at which time Request 10 will be moot. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys (212) 637-2324 cc: Counsel of Record (by ECF) EFTA00103755

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

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s Assistant United States Attorneys (212) 637-2225 212 EFTA00100179

rael, 05 Cr. 1039 (CM) 194 United States v. Reeves, et aL, 16 Cr. 372 (VEC) 194 United States v. Serrano, No., 13 Cr. 58 88 United States v. Ulbricht, No., 14 Cr. 68 83 United States v. Vickers, 13 Cr. 128 154 United States v. Wedd, 15 Cr. 616 179 xxv EFTA00095092 UNITED STATES DISTRICT

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

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

sons, the Court should deny all twelve of the defendant's pre-trial motions. Dated: New York, New York February 26, 2021 Respectfully submitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys (212) 637-2225 211 EFTA00095303

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.

ernment obtains the boots and makes them available for inspection by the defendant, at which time Request 10 will be moot. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys cc: Counsel of Record (by ECF) EFTA00015873

o, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16, 2021) (citing Bowman Data, Co., 341 U.S. at 220 (1951)); see also United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and objects to be introduced at criminal trials"),

in response to Rule 17(c) subpoenas be treated as confidential under the protective order and disclosed to the Government. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys cc: Counsel of Record (by ECF) EFTA00018246

o, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16, 2021) (citing Bowman Dab), Co., 341 U.S. at 220 (1951)); see also United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and objects to be introduced at criminal trials"),

in response to Rule 17(c) subpoenas be treated as confidential under the protective order and disclosed to the Government. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys cc: Counsel of Record (by ECF) EFTA00022037