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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
records documenting the substance of the call. The Government has not identified any records that suggest AUSA- I ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
who participated in the February 2016 meeting. The Government is producing all identified emails to defense counsel today. 63 EFTA00095155 with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
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
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
Entities connected to both Giglio and Pottinger, Edwards

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATIONCollins
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATIONBortnovsky
PERSON
Audrey Strauss
PERSON
Scarlett Johansson
PERSONThompson
PERSONJencks Act
PERSONAnnabi
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATIONTracy
PERSON
Eric Holder
PERSON
David Boies
PERSON