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

(JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. Florence, 456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Mt1 Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Ha. 2012) 23,24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98

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

JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. Florence, 456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 23, 24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 9

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

JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. Florence, 456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 23, 24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 9

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

JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 48 United States v. Florence, 456 F.2d 46 (4th Cir. 1972) 201 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 19, 20 United States v. Forde, 740 F.Supp.2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98

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

the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int 'I Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airline employee based on