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

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("`[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00100146 Particulars are nec

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

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00077811 Particulars are nec

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

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("c[E]videntiary detail is not the function of the bill of particulars.' 179 EFTA00039626 Particulars are nec

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

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 174 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 120, 127, 133, 135 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) (m[E]videntiary detail is not the function of the bill of particulars.' Particulars are necessary only where ind

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

(JPO), 2017 WL 1608905 (S.D.N.Y. Apr. 28, 2017) 267 United States v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 2

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

01 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) ("1E]videntiaty detail is not the function of the bill of particulars.' 179 EFTA00103204 Particulars are nece