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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
and Order 71 EFTA00100038 On or about April 9, 2019, granted the Government's application and issued a memorandum and order. (Del Mot. 3, Exs. F & G). Gat forth 12). Thief Judge which la,ould be exparOppose unsealing[] reasoriallatective ord was the • the oraentseit, the court's levet
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
00077703 On or about April 9, 2019, Chief Judge McMahon granted the Government's application and issued a memorandum and order. (Def. Mot. 3, Exs. F & G). The Court noted that while the Government's application was procedurally "[i]rregular," there was precedent for granting the Government's request
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
00039518 On or about April 9, 2019, Chief Judge McMahon granted the Government's application and issued a memorandum and order. (Def. Mot. 3, Exs. F & G). The Court noted that while the Government's application was procedurally "[i]rregular," there was precedent for granting the Government's request
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
and Order On or about April 9, 2019, Chief Judge McMahon granted the Government's application and issued a memorandum and order. (Def. Mot. 3, Exs. F & G). The Court noted that while the Government's application was procedurally 10r-regular," there was precedent for granting the Government's request
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
00103096 On or about April 9, 2019, Chief Judge McMahon granted the Government's application and issued a memorandum and order. (Def. Mot. 3, Exs. F & G). The Court noted that while the Government's application was procedurally "[i]rregular," there was precedent for granting the Government's request
Entities connected to both Giglio and F & G

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONCollins
PERSONFBI
ORGANIZATION
Southern District of New York
ORGANIZATIONthe Southern District
LOCATION
Audrey Strauss
PERSONBortnovsky
PERSON
Scarlett Johansson
PERSONThompson
PERSONJencks Act
PERSONAnnabi
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATION
Eric Holder
PERSONRusso
PERSONTracy
PERSON