Epstein Secrets

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

rticulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied

the fifth photograph was the defendant, with whom Indiivudal-1 grew up with and last had contact in July 2019 during a wedding. Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: Assistant United States Attorneys 06.20.2018 EFTA00067059

e feds he said he 2 The Government intends to disclose the names of the witnesses referenced herein in advance of trial along with other Giglio and Jencks Act materials. The Government is available to discuss a schedule for those disclosures at your convenience. 06.20.2018 EFTA00067057 Page 4 might gi

Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings

f the three Minor Victims listed in the Indictment by November 23, 2020. Fourth, the defense asked that the Government provide the defense with all Jencks Act material by November 23, 2020. In response, the Government agreed to the first two conditions, but did not agree to the second two conditions. Accor

ly, the Government respectfully requests that, should an adjournment be granted, any new trial date be set for March 2022. Respectfully submitted, AUDREY STRAUSS United States Attorney Assistant United States Attorneys Southern District of New York Cc: All Counsel of Record (By ECF) 5 In particular, AUSA

tion to the MDC, the Government has informed defense counsel that the undersigned will hand deliver the Government's first production of Giglio and Jencks Act material to the MDC to minimize any delay in the defendant's ability to access that material when it is produced. EFTA00092740 Page 8 that its i

be happy to consider it. 3 EFTA00095589 Please let us know if you have any questions or would like to discuss the foregoing. Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: s/ Assistant United States Attorneys 4 EFTA00095590

ernment's letter dated October 28, 2020, with regard to your many requests for information that fall within the scope of the Government's Giglio and Jencks Act obligations, we intend to produce all such material in advance of trial and remain available to confer generally regarding a mutual schedule for pr

ICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

Particulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

Particulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

Particulars Is Not Warranted 174 1. Applicable Law 174 2. Discussion 178 B. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied

ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -

Particulars Is Not Warranted 173 1. Applicable Law 174 2. Discussion 177 A. The Defendant's Requests for Early Production of a Witness List and Jencks Act Material Should Be Denied 182 1. Applicable Law 182 2. Discussion 183 A. The Defendant's Additional Requests for Disclosure Should Be Denied