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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
d the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See, e.g., Gov't Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material
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
d the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See, e.g., Gov't Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material
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
d the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See, e.g., Gov't Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material
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
ourt and the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See Gov't Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material
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
d the defense regarding its approach to obtaining and reviewing files, including other agency files, that may be relevant to this case. (See, e.g., Gov't Letter dated October 7, 2020, Dkt. No. 63). Consistent with that commitment, the Government has completed an initial review of its files for Brady material
Entities connected to both Bortnovsky and Gov't Letter

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Giglio
PERSONAnnabi
PERSONRusso
PERSON
Southern District of New York
ORGANIZATIONThompson
PERSONEmmy Taylor
PERSONTracy
PERSONWalker
PERSONCollins
PERSON
Brady
PERSON
Scarlett Johansson
PERSONCoppa
PERSONthe White Plains Division
ORGANIZATIONMandell
PERSONMahabub
PERSON
Torres
PERSONTrippe
PERSON