8
Shared Docs
5
Same-Page
8 / 8
Mentions
in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.
. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
ioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Afri
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari
ioned. He appears to relish the company of super-rich oil billionaires from the Middle East, North Afri
ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked Dexter and Marie t
JN Document 195 Filed 04/05/21 Page 4 of 11 Page 4 evidence; it cannot be used as a device to gain understanding or explanation." United States v. Rich, No. 83 Cr. 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984) (internal quotation marks omitted) (emphasis added). Accordingly, subpoenas that
Page: EFTA00018239 →vulnerable witnesses"). That is particularly true where the subpoena at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material given that the Government has a cognizable interest in "controlling the timing of disclosures as to" witnesses who are expected to
Page: EFTA00018240 →. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet
Page: EFTA00020303 →ufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations under Brady
Page: EFTA00020304 →sible in EFTA00022029 --- PAGE BREAK --- Page 4 evidence; it cannot be used as a device to gain understanding or explanation." United States v. Rich, No. 83 Cr. 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984) (internal quotation marks omitted) (emphasis added). Accordingly, subpoenas that
Page: EFTA00022030 →vulnerable witnesses"). That is particularly true where the subpoena at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material given that the Government has a cognizable interest in "controlling the timing of disclosures as to" witnesses who are expected to
Page: EFTA00022031 →Entities connected to both Marc Rich and Giglio

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Lesley Groff
PERSONDarren Indyke
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Martha Stewart
PERSON
Alan Dershowitz
PERSON
Woody Allen
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
John F. Kennedy
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
Joe Biden
PERSON
United States
LOCATION
Alfredo Rodriguez
PERSON
Harry Reid
PERSON
Bill Clinton
PERSON