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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
ed States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 124, 132 United States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00099963 United States v. Sweig, 441
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
ed States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 124, 132 United States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00077628 United States v. Sweig, 441
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
ed States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 124, 132 United States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00039443 United States v. Sweig, 441
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
States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 87, 93, 94 United States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 151, 152, 153 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 120, 127 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 115 United States v. Sweig, 441 F.2d 114 (2d C
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
ed States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 124, 132 United States v. Stringer, 730 E 3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00103021 United States v. Sweig, 441
Entities connected to both Giglio and Strohm

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Supreme Court
ORGANIZATIONCollins
PERSONthe Southern District
LOCATIONEmmy Taylor
PERSONWerner
PERSON
Chris Tucker
PERSON
Southern District of New York
ORGANIZATION
Julie K. Brown
PERSON
Michael Jackson
PERSONLeon Black
PERSON
Colorado
LOCATIONThompson
PERSON
Virginia Giuffre
PERSON