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

United States v. Savage, 970 F.3d 217 (3d Cr. 2020) 302 United States v. Scala, 388 F. Supp. 2d 396 (S.D.N.Y. 2005) 67,68,71 United States v. Scarpa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scarpa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 201

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

Conzielle, 171 F.3d at 752 (citations omitted). The burden for proving both prongs of the standard rests squarely on the defendant. United States v. Scarpa, 913 F.3d 993, 1014 (2d Cir. 1990); United States v. Rubin, 609 F.2d 51, 66 (2d Cir. 1979); United States v. Ricco, 549 F.2d 264, 272 (2d Cir. 1977

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

Conzielle, 171 F.3d at 752 (citations omitted). The burden for proving both prongs of the standard rests squarely on the defendant. United States v. Scarpa, 913 F.3d 993, 1014 (2d Cir. 1990); United States v. Rubin, 609 F.2d 51, 66 (2d Cir. 1979); United States v. Ricco, 549 F.2d 264, 272 (2d Cir. 1977

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

Conzielle, 171 F.3d at 752 (citations omitted). The burden for proving both prongs of the standard rests squarely on the defendant. United States v. Scarpa, 913 F.3d 993, 1014 (2d Cir. 1990); United States v. Rubin, 609 F.2d 51, 66 (2d Cir. 1979); United States v. Ricco, 549 F.2d 264, 272 (2d Cir. 1977

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

Cornielle, 171 F.3d at 752 (citations omitted). The burden for proving both prongs of the standard rests squarely on the defendant. United States v. Scarpa, 913 F.3d 993, 1014 (2d Cir. 1990); United States v. Rubin, 609 F.2d 51, 66 (2d Cir. 1979); United States v. 42 EFTA00103067 Ricco, 549 F.2d 264

21. The Government has also agreed to provide notice pursuant to Federal Rule of Evidence 404(b), a proposed witness list, Jencks Act material, and Giglio material 45 days in advance of trial. As a result, the defense will receive many of these disclosures weeks in advance of when is typical for crimi

repeatedly noted that such evidence is not exculpatory. (See, e.g., Dkt. No. 65 at 1-2; Dkt. No. 204 at 47-48 (citing, inter alia, United States v. Scarpa, 897 F.2d 63, 70 (2d Cir. 1990) ("A defendant may not seek to establish h[er] innocence . . . through proof of the absence of criminal acts on speci

dy requests." As an initial matter, we take seriously our disclosure obligations, including those arising under Rule 16, Brady and its progeny, and Giglio v. United States, 405 U.S. 150 (1972) and its progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of whe

ed periods or uncharged events—to rebut the Government's evidence with respect to the charged crimes or events. Dkt. 65; see, e.g., United States v. Scarpa, 897 F.2d 63, 70 (2d Cir. 1990) ("A defendant may not seek to establish his innocence . . . through proof of the absence of criminal acts on [other