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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
he defense to file a motion under Rule 412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) EFTA00065525
nited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materi
10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00073595
(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
MERICA S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materi
10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00090281
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materi
ed by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00090425
nited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materi
arking directly refers to the specific paragraphs of the Protective Order that govern today's production. EFTA00094633 Page 2 Very truly yours, DAMIAN WILLIAMS United States Attorney Assistant United States Attorneys EFTA00094634
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materi
ed by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. Very truly yours, DAMIAN WILLIAMS United States Attorney by: W Assistant United States Attorneys EFTA00095750
Entities connected to both Giglio and DAMIAN WILLIAMS

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONSouthern District
LOCATIONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONFBI
ORGANIZATIONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONLaura Menninger
PERSONCohen & Gresser LLP
ORGANIZATIONJencks Act
PERSON
Christian Everdell
PERSONSecond Circuit
ORGANIZATION
Denver
LOCATION
Barneys New York
ORGANIZATION
Foreman
PERSONSkelos
PERSON