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

d 48 (2d Cir. 2017). Zafiro v. United States, 506 U.S. 534 (1993) 151 passim 209,210,220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §1623(a) 118 18 U.S.C. § 1591 152 18 U.S.C. § 1623 3,115 18

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

48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.C. § 1591 152 18 U.S.C. § 1623 3, 115 18

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

48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.C. § 1591 152 18 U.S.C. § 1623 3, 115 18

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

865 F.3d 48 (2d Cir. 2017) passim Zafiro v. United States, 506 U.S. 534 (1993) 140, 147 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 201 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 85 Statutes 18 U.S.C. §1623(a) 119 18 U.S.C. § 371 2, 152, 156, 169 18 U.S.C. § 1001(

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

48 (2d Cir. 2017) Zafiro v. United States, 506 U.S. 534 (1993) 209, 151 passim 210, 220 Zicarelli v. Dietz, 633 F.2d 312 (3d Cir. 1980) 293 Zietzke v. United States, 426 F. Supp. 3d 758 (W.D. Wash. 2019) 121 Statutes 18 U.S.C. §I623(a) 118 18 U.S.C. § 1591 152 18 U.S.C. § 1623 3, 115 18