Epstein Secrets

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

tes v. Griffith, No. 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 264 United States v. Guerrier, 18 Cr. 284 (JSR) 286 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. 1, 2020) 261 United State

whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and

ct material in light of Coppa). Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regardinga schedule for pretria

015,2016, 2017,and 2018 survey data. (Id.). 208 EFTA00100175 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

tates v. GrWith, No. 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 264 United States v. Guerrier, 18 Cr. 284 (JSR) 286 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United State

whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and

ct material in light of Coppa). Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regarding a schedule for pretri

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00077840 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

tates v. GrWith, No. 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 264 United States v. Guerrier, 18 Cr. 284 (JSR) 286 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United State

whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and

ct material in light of Coppa). Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regarding a schedule for pretri

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00039655 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

Greer, 956 F. Supp. 525 (D. Vt. 1997) 49 United States v. Griffith, 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 172 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 208 United States v. Halkbank, 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. 1, 2020) 170 United States v.

of Coppa). 182 EFTA00095274 Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regarding a schedule for pretri

whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and

P]erfectly proportional representation is not required, since no source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it

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

ates v. Grffith, No. 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 264 United States v. Guerrier, 18 Cr. 284 (JSR) 286 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 300 United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512 (S.D.N.Y. Oct. I, 2020) 261 United State

whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and

ct material in light of Coppa). Typically in this District, and as is the case here, the Government confirms that it will produce 3500 material and Giglio (or impeachment) material reasonably in advance of trial, and will engage in good faith discussions with the defense regarding a schedule for pretri

5, 2016, 2017, and 2018 survey data. (Id.). 208 EFTA00103233 source list will be an exact statistical mirror of the community." United States v. Guzman, 337 F. Supp. 140, 143 (S.D.N.Y. 1972); see also Taylor, 419 U.S. at 538. The mere fact that a jury selection system is imperfect does not make it