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

7) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

017) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

017) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123

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

8, 147, 149 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 97 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 93 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 167 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 166 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 87

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) 274 United States v. Roberts, 660 F.3d 149 (2d Cir. 2011) 138 United States v. Roberts, 852 F.2d 671 (2d Cir. 1988) 132 United States v. Rolan-Zapata, 916 F.2d 795 (2d Cir. 1990) 256 United States v. Rosa, 11 F.3d 315 (2d Cir. 1993) 253 United States v. Rosa, 626 F.3d 56 (2d Cir. 2010) 123