Epstein Secrets

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

ed States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 153, 154 United States v. Schneider, 801 F.3d 186 (3d Cir. 2015) 51,52,54,57 United States v. Seabrook, No. 10 Cr. 87 (DAB), 2010 WL 5174353 (S.D.N.Y. Dee. 14, 2010) 282 United States v. Sensi, No. 08 Cr. 253, 2010 WL 2351484 (D. Conn. June 7, 2010

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

. ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial."); United States v. Seabrook, No. 10 Cr. 87 (DAB), 2010 WL 5174353, at *4 (S.D.N.Y. Dec.14, 2010) ("The Government represents to the Court that it is aware of its Brady, Giglio

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

. ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial."); United States v. Seabrook, No. 10 Cr. 87 (DAB), 2010 WL 5174353, at *4 (S.D.N.Y. Dec. 14, 2010) ("The Government represents to the Court that it is aware of its Brady, Gigli

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

. ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial."); United States v. Seabrook, No. 10 Cr. 87 (DAB), 2010 WL 5174353, at *4 (S.D.N.Y. Dec. 14, 2010) ("The Government represents to the Court that it is aware of its Brady, Gigli

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

. ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial."); United States v. Seabrook, 10 Cr. 87 (DAB), 2010 WL 5174353, at *4 (S.D.N.Y. Dec. 14, 2010) ("The Government represents to the Court that it is aware of its Brady, Giglio, J

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

. ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial."); United States v. Seabrook, No. 10 Cr. 87 (DAB), 2010 WL 5174353, at *4 (S.D.N.Y. Dec. 14, 2010) ("The Government represents to the Court that it is aware of its Brady, Gigli