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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
ent's proof to particulars furnished," it can "restrict unduly the Government's ability to present its case." Henry, 861 F. Supp. at 1197; see also Mitlof, 2014 WL 4243657, at *2 (recognizing that "care must be taken" because "[t]he government's presentation of evidence at trial is limited to the part
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
Page: EFTA00023912 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00023912 →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
Page: EFTA00030945 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00030945 →Entities connected to both Giglio and Mitlof

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONBortnovsky
PERSON
Audrey Strauss
PERSONSecond Circuit
ORGANIZATIONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONLaura Menninger
PERSON
Jencks
PERSONTrippe
PERSONMahabub
PERSON
Christian Everdell
PERSONMandell
PERSONGibson
PERSONWalsh
PERSONBobbi C. Sternheim
PERSON
Torres
PERSONDistrict Court for the Southern District of New York
ORGANIZATIOND'Amico
PERSON