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d States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 8,20,27 United States v. Fennel!, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284,286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F
harged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The d
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
tates v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 192, 194 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 167 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 48 United States v. F
ismissal of an indictment filed within the statute of limitations must establish that the Government acted intentionally, scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. 20 The de
not been dismissed on other grounds." (Def. Mot. 7 at 1). As noted above, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial, consistent with whatever schedule the parties agree upon or this Court sets. The Court should re
39 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 496 F. Supp. 2d 279 (S.D.N.Y. 2007) 284, 286 United States v. Figueroa, 618 F.2d 934 (2d Cir. 1980) 255 United States v. Fiumano, No. 14 Cr. 518 (JFK), 2016 WL 1629356 (S.D.N.Y. Apr. 25, 2016) 70 United States v. F
arged crimes and the victims referenced in the Indictment. Additionally, many of the defendant's requests fall within the scope of the Government's Giglio and Jencks Act obligations, which the Government intends to produce at the appropriate stage in the litigation, well in advance of trial. The defe
. Mot. 7 at 1). As noted above and discussed further in Section X, infra, the Government has complied with its Rule 16 obligations and will produce Giglio and Jencks Act materials well in advance of trial. The Court should reject the defendant's invitation to defer ruling on this motion. See, e.g., Uni
Entities connected to both Figueroa and Giglio

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Bradley Edwards
PERSON
Southern District of New York
ORGANIZATIONFBI
ORGANIZATION
Scarlett Johansson
PERSONJane Doe
PERSONCollins
PERSON
Supreme Court
ORGANIZATIONEmmy Taylor
PERSON
David Boies
PERSONThompson
PERSONJeffrey Pagliuca
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Audrey Strauss
PERSONBortnovsky
PERSON
George W. Bush
PERSON