Epstein Secrets

in the Government'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

ged crimes, nor must the Government provide a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States v. Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion for bill of particulars and explaining that the defendant "need no

in the Government'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

ged crimes, nor must the Government provide a preview of the evidence or legal theories it intends to present at trial. See, e.g., United States v. Dupigny, 18 Cr. 528 (JMF), 2019 WL 2327697, at *2 (S.D.N.Y. May 30, 2019) (denying motion for bill of particulars and explaining that the defendant "need no

ited States v. Smith, 19 Cr. 324 (BAH), 2020 WL 5995100, at *19 (D.D.C. Oct. 9, 2020). Here, the Government produced to the defense a witness list, Giglio material, Jencks Act material, and notice pursuant to Federal Rule of Evidence 404(b) by October 11, 2021, or 7 weeks in advance of trial. The Gove

131 (PAE) (S.D.N.Y. Apr. 29, 2020) (Dkt. No. 384) (setting a Rule 412 deadline of October 15, 2020, for a November 9, 2020 trial); United States v. Dupigny, 18 Cr. 528 (JMF) (S.D.N.Y. Oct. 23, 2019) (Dkt. No. 202) (requiring a "finalized proffer of evidence" the defense sought to admit under Rule 412 b

(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

ncluding the psychological relationship between pimps and the women prostituted by them"); Notice and Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. Nos. 180-1, 198 (permitting expert testimony on "the psychological relationship between a pimp and the woman