6
Shared Docs
3
Same-Page
6 / 6
Mentions
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
oviding a time and place before trial for the inspection of specific materials that the parties intend to offer into evidence. See United States v. Tagliaferro, 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. U
Page: EFTA00018237 →vulnerable witnesses"). That is particularly true where the subpoena at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material given that the Government has a cognizable interest in "controlling the timing of disclosures as to" witnesses who are expected to
Page: EFTA00018240 →dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
Page: EFTA00020300 →. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
Page: EFTA00020303 →oviding a time and place before trial for the inspection of specific materials that the parties intend to offer into evidence. See United States v. Tagliaferro, 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. U
Page: EFTA00022028 →vulnerable witnesses"). That is particularly true where the subpoena at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material given that the Government has a cognizable interest in "controlling the timing of disclosures as to" witnesses who are expected to
Page: EFTA00022031 →Entities connected to both Giglio and Tagliaferro

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Brady
PERSON
United States
LOCATION
Prince Andrew
PERSON
Audrey Strauss
PERSON
David Boies
PERSONSecond Circuit
ORGANIZATION
Cynthia Nixon
PERSONSkelos
PERSON
Barneys New York
ORGANIZATIONNachamie
PERSONNORMAN SEABROOK
PERSON
ALISON J. NATHAN
ORGANIZATION
Alison J. Nathan
PERSON
Marc Rich
PERSONUlbricht
PERSON
Michael Avenatti
PERSON
Sarah Ferguson
PERSONGiampa
PERSON