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

2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), aff'd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts

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

to Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency .. ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00100170 Southern District, cases are commonly transferred from one courthouse to an

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

, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts

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

Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency . . . ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00077835 Southern District, cases are commonly transferred from one courthouse to an

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

, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts

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

Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency . . . ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00039650 Southern District, cases are commonly transferred from one courthouse to an

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

C), 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007) United States v. Snyder, 159, 160, 167 162 139 668 F.2d 686 (2d Cir. 1982) 44, 53 United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) 203 United States v. Spears, 159 F.3d 1081 (7th Cir. 1999) 43, 45, 46 United States v. Sprouts, 282 F.3d 1

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

Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency . . . ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the Southern District, cases are commonly transferred from one courthouse to another, including cas

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

, 2007 WL 980431 (S.D.N.Y. Apr. 3, 2007), affd, F. App'x 636 (2d Cir. 2009) United States v. Snyder, 668 F.2d 686 (2d Cir. 1982) United States v. Soares, 66 F. Supp. 2d 391 (E.D.N.Y. 1999) United States v. Spears, 206 63, 78 295 159 F.3d 1081 (7th Cir. 1999) 62, 66, 67 United States v. Sprouts

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

to Uniondale for the retrial "to accommodate trial congestion in the court's calendar during a period of judicial emergency .. ." United States v. Soares, 66 F. Supp. 2d 391, 397 n.2 (E.D.N.Y. 1999). In the 203 EFTA00103228 Southern District, cases are commonly transferred from one courthouse to an