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

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified pos &WadiDef. Mem. 3, Ex. E at 2-3). The U

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

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through

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

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through

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 Department reports. Although AUSA-1 does not now recall the attorneys providing her with any 65 EFTA00095157 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at

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

er notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.32 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through