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737 KB

Extraction Summary

6
People
2
Organizations
1
Locations
2
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 737 KB
Summary

This legal document is a filing by the Government in Case 1:20-cr-00330-PAE, dated April 16, 2021. The Government argues that its proposed schedule for providing discovery materials (including Section 3500, Giglio, and Jencks Act information) to the defense is adequate and even exceeds the standard practice in the district for high-profile cases. The Government offers to produce non-testifying witness statements eight weeks before trial and testifying witness materials four weeks in advance, asserting this provides ample time for the defense to prepare.

People (6)

Name Role Context
Gallo
Mentioned as the defendant in a cited case, United States v. Gallo, No. 98 Cr. 338.
Gatto
Mentioned as a defendant in a cited high-profile trial case, Gatto, 17 Cr. 686 (LAK).
Blaszczak
Mentioned as a defendant in a cited high-profile trial case, Blaszczak, 17 Cr. 357 (LAK).
Skelos
Mentioned as a defendant in a cited high-profile trial case, Skelos, 15 Cr. 317 (KMW).
Silver
Mentioned as a defendant in a cited high-profile trial case, Silver, 15 Cr. 93 (VEC).
Ulbricht
Mentioned as a defendant in a cited high-profile trial case, Ulbricht, 14 Cr. 68 (KBF).

Organizations (2)

Name Type Context
Government government agency
Refers to the prosecution in the legal case, outlining its intentions for providing discovery materials.
United States government
Mentioned as the plaintiff in the cited case, United States v. Gallo.

Timeline (2 events)

The upcoming trial in case 1:20-cr-00330-PAE, which is stated to be more than four months away from the date of the document.
this District
Government defense
The Government outlines its plan for disclosing witness materials (Section 3500, Giglio, Jencks Act) to the defense, offering to provide non-testifying witness statements eight weeks before trial and testifying witness statements four weeks before trial.
this District
Government defense

Locations (1)

Location Context
Abbreviation for the Southern District of New York, the court district where the case United States v. Gallo was hear...

Relationships (1)

Government adversarial defense
The document is a legal filing in which the Government is arguing against the defense's position regarding the timing of discovery and witness material disclosure before a trial.

Key Quotes (2)

"is more than adequate."
Source
— United States v. Gallo (A quote from the United States v. Gallo case, referring to the Government's plan to produce impeachment material sufficiently in advance of witness testimony.)
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Quote #1
"[T]he Government has indicated that it is aware of its obligations under Giglio . . . and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness’s testimony to allow adequate time to prepare for cross-examination. These representations are sufficient."
Source
— United States v. Gallo (A quote from the United States v. Gallo case, affirming that the Government's stated commitment to its disclosure obligations is sufficient.)
DOJ-OGR-00003145.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,213 characters)

Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 211 of 239
with the regular practice in this District, the Government intends to make Section 3500 material available to the defense at the same time as impeachment material, [and that] in order to avoid any delay in the trial, the Government will produce such material sufficiently in advance of each Government witness’s testimony’ . . . is more than adequate.”); United States v. Gallo, No. 98 Cr. 338 (JGK), 1999 WL 9848, at *8 (S.D.N.Y. Jan. 11, 1999) (“[T]he Government has indicated that it is aware of its obligations under Giglio . . . and the Jencks Act and that it will provide the required information to the defendants in accordance with its responsibilities under Giglio and the Jencks Act sufficiently in advance of each witness’s testimony to allow adequate time to prepare for cross-examination. These representations are sufficient.”).
2. Discussion
Trial is still more than four months away. The degree of complexity to this case, and the volume of discovery, is on par with other recent high-profile trials in this District, and in those cases witnesses have typically been disclosed approximately three to four weeks before trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KBF). As the Government has noted for some time now, the Government intends to match or even go above and beyond that practice in this case. Specifically, the Government has offered repeatedly to provide non-testifying witness statements to the defense as much as eight weeks before trial, thereby allowing extra time for the defense to determine whether it wishes to call any of the witnesses the Government does not intend to present at trial, and to provide testifying witness statements and Giglio material as much as four weeks in advance of trial. Given that the defense has already been able to initiate its investigation of the charges, and given that the discovery makes clear who the three minor victims are, eight weeks should be ample time to review non-testifying witness statements, and four weeks is more than enough time
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