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ment cannot provide "mountains of documents to defense counsel" as a substitute for a bill of particulars where one would otherwise be required, see Bortnovsky, 820 F.2d at 575, the provision of voluminous discovery in combination with some guidance about what is most relevant can vitiate a need for furthe
ent's proof to particulars furnished," it can "restrict unduly the Government's ability to present its case." Henry, 861 F. Supp. at 1197; see also Mitlof, 2014 WL 4243657, at *2 (recognizing that "care must be taken" because "[t]he government's presentation of evidence at trial is limited to the part
vent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Indictment contains a written statement of the essential facts constituting the offenses charged, and it des
Page: EFTA00023911 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00023912 →vent surprise, and to interpose a plea of double jeopardy should [the defendant] be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Indictment contains a written statement of the essential facts constituting the offenses charged, and it des
Page: EFTA00030944 →mation with respect to where, when, and with whom the Government will charge the defendant with conspiring are routinely denied."); United States v. Mitlof, 165 F. Supp. 2d 558, 569 (S.D.N.Y. 2001) ("What defendant seeks is in the nature of the `wheres, whens and with whoms' that [c]ourts have held to
Page: EFTA00030945 →Entities connected to both Bortnovsky and Mitlof

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Giglio
PERSONMahabub
PERSONMandell
PERSONTrippe
PERSON
Torres
PERSONGibson
PERSONWalsh
PERSONSecond Circuit
ORGANIZATION
Audrey Strauss
PERSON
Jencks
PERSON
Department of Justice
ORGANIZATIOND'Amico
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONBobbi C. Sternheim
PERSONLaura Menninger
PERSON
Barrera
PERSON