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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
nited States v. Savage, 970 F.3d 217 (3d Cir. 2020) 302 United States v. Scala, 388 F. Supp. 2d 396 (S.D.N.Y. 2005) 67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 201
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
nited States v. Savage, 970 F.3d 217 (3d Cir. 2020) 302 United States v. Scala, 388 F. Supp. 2d 396 (S.D.N.Y. 2005) 67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 201
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
nited States v. Savage, 970 F.3d 217 (3d Cir. 2020) 210 United States v. Scala, 388 F. Supp. 2d 396 (S.D.N.Y. 2005) 46, 47, 49 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 48 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) 159, 160, 162, 164 United States v. Scaipa, 913 F.3d 993 (
Entities connected to both Giglio and Scaipa

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
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATIONAnnabi
PERSONTracy
PERSONRusso
PERSON
Eric Holder
PERSON