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This legal document is a filing from the U.S. Attorney for the Southern District of New York, arguing against a defense position regarding witness availability. The prosecution cites the precedent of *United States v. Jones*, where a judge rejected a similar defense attempt to compel the government to immunize a witness. The filing concludes that since the defense had the opportunity to call numerous witnesses, including Virginia Roberts, there is no reason to deviate from the standard jury instruction on the equal availability of witnesses.