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ved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a smal
oyed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
ved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a smal
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
ved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a smal
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
ved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a smal
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
ved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a smal
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
D.N.Y. 2018) 20 United States v. Bryan, 868 F.2d 1032 (9th Cir. 1989) 24 United States v. Carr, 424 F.3d 213 (2d Cir. 2005) 12 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 20 ii EFTA00027309 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 4 of 34 Unite
Page: EFTA00027309 →80) 13 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 29, 30, 31 United States v. Armstrong, 517 U.S. 456, (1996) passim United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015) 19
Page: EFTA00027309 →D.N.Y. 2018) 20 United States v. Bryan, 868 F.2d 1032 (9th Cir. 1989) 24 United States v. Carr, 424 F.3d 213 (2d Cir. 2005) 12 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 20 ii EFTA00031265 --- PAGE BREAK --- United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) United States v
Page: EFTA00031265 →0) 13 United States v. Alamelz, 341 F.3d 167 (2d Cir. 2003) 29, 30, 31 United States v. Armstrong, 517 U.S. 456, (1996) passim United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015) 19
Page: EFTA00031265 →r-00830-AT Document 36 Filed 06/09/20 Page 5 of 9 arises where the Government conducts a joint investigation with another agency." United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (internal quotation marks and citation omitted). In determining whether the prosecution has conducted a jo
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
r-00830-AT Document 36 Filed 06/09/20 Page 5 of 9 arises where the Government conducts a joint investigation with another agency." United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (internal quotation marks and citation omitted). In determining whether the prosecution has conducted a jo
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
r-00830-AT Document 36 Filed 06/09/20 Page 5 of 9 arises where the Government conducts a joint investigation with another agency." United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (internal quotation marks and citation omitted). In determining whether the prosecution has conducted a jo
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
Entities connected to both Collins and Avellino

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Stephen Hawking
PERSON
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
Paul Ryan
PERSON
Alfredo Rodriguez
PERSONthe Southern District
LOCATION
Bill Richardson
PERSON
Brady
PERSON
Bernie Sanders
PERSON
Martha Stewart
PERSON
Giglio
PERSON
Southern District of New York
ORGANIZATION