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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
7,262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001 ) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
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
7, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
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
7, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
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
60, 163, 171 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 159 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 97 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 152, 159, 162 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 59 Un
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
7, 262 United States v. Mulder, 273 F.3d 91 (2d Cir. 2001) 241, 242 United States v. Mullens, 536 F.2d 997 (2d Cir. 1976) 139 United States v. Murgio, 209 F. Supp. 3d 698 (S.D.N.Y. 2016) 231, 241, 247 United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178 (S.D.N.Y. July 13, 2010) 86 Un
Entities connected to both Giglio and Murgio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Southern District of New York
ORGANIZATIONthe Southern District
LOCATIONFBI
ORGANIZATIONCollins
PERSON
Scarlett Johansson
PERSON
Supreme Court
ORGANIZATIONThompson
PERSONBortnovsky
PERSON
David Boies
PERSON
Audrey Strauss
PERSONJencks Act
PERSONEmmy Taylor
PERSONMarkiewicz
PERSONNejad
PERSONAnnabi
PERSON