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tes v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S
Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied 185 XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper 193 A. Background 194 1. The SDNY and Local Rules for the Division of Business 194 2. The SDNY Any Plan 19
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
eks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XL The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29,2020, amidst a global pandemic that suspendedgrand juries across the country, the Government sought
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
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
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
ould consider not just the text of the Indictment, but also discovery and other information supplied to the defendant to date. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987); see also, e.g., Pierre-Louis, 2018 WL 4043140, at *7 (denying request for bill of particulars where indictment ch
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
Entities connected to both Bortnovsky and The Use of a Grand Jury Siting

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Giglio
PERSONAnnabi
PERSONThompson
PERSON
Southern District of New York
ORGANIZATIONRusso
PERSONEmmy Taylor
PERSONCollins
PERSONTracy
PERSONWalker
PERSON
Brady
PERSON
Scarlett Johansson
PERSONCoppa
PERSONthe White Plains Division
ORGANIZATIONMahabub
PERSONMandell
PERSONTrippe
PERSON
Torres
PERSON