MEMORANDUM AND ORDER
PAULEY, District Judge.
Defendant James H. Giffen ("Defendant" or "Giffen") is charged in a 65-count superseding indictment (the "Indictment") with making unlawful payments totaling more than $78 million to Nurlan Balgimaev, the former Prime Minister and Oil Minister of the Republic of Kazakhstan, and Nursultan Nazarbaev, the current President of Kazakhstan (collectively, "senior Kazakh officials"), in violation of the Foreign...
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