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97) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017). Zafiro v. United States, 506 U.S. 534 (1993) 151 passim 209,210,220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §1623(a) 118 18 U.S.
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
) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.
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
) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.
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
(1997) 104 Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) passim Zafiro v. United States, 506 U.S. 534 (1993) 140, 147 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 201 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 85 Statutes 18 U.S.C. §1623(a) 119 18 U.S.C
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
) Weingarten v. United States, 865 F.3d 48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.
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
re of trauma psychology. For instance, attached as Exhibit A are some of the articles that have been provided by Dr. and inform her testimony. See Dietz, "Grooming and Seduction," 33 J. of Interpersonal Violence 28, 34 (2018) The concepts of attachment and grooming encompass a variety of established
(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
Entities connected to both Dietz and Giglio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATIONCollins
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATION
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATION
Audrey Strauss
PERSONJeffrey Pagliuca
PERSONBortnovsky
PERSONThompson
PERSONWalker
PERSON
Eric Holder
PERSONJencks Act
PERSON
David Boies
PERSON