Epstein Secrets

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

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

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

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

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

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

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

e district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.")); United States v. Salamelz, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit "presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively

rial. The government's assertion that it can withhold production of Accuser-4's prior statements because they are merely impeachment material under Giglio, and do not rise to the level of exculpatory material under Brady, is unsupported and flatly incorrect. (Opp. 20-22). The government admits that Ac

States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 7 United States v. Rivera, 844 F.2d 916 (2d Cir. 1988) 9 ii EFTA00104413 United States v. Salamelz, 152 F.3d 88 (2d Cir. 1998) 7 United States v. Torres, 719 F.2d 549 (2d Cir. 1983) 15 iii EFTA00104414 Ghislaine Maxwell respectfully submit