Epstein Secrets

d "some evidence tending to show the existence" of the essential elements of a due process violation. Id., ECF No. 37 at 5 (quoting United States v. Armstrong, 517 U.S. 456, 469 (1996)). The government pointed to a standard typically applied in suppression cases—i.e., that discovery is appropriate only "i

because she thought there were questions about whether justice was done, and it's really had an impact," Hirsch said. "That's what it's all about." Berman's comments at the news conference — which came in response to a question about whether prosecutors had obtained new information about Epstein, who p

nhouse on Saturday, investigators seized photographs of nude underage girls, federal prosecutors said. "The alleged behavior shocks the conscience," Geoffrey S. Berman, the United States attorney in Manhattan, said on Monday. Prosecutors said they were moving to seize Mt Epstein's townhouse. Mr. Epstein, however,

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00027307 --- PAGE BREAK --- Case 1:

r. 2020) 26 Standefer v. United States, 447 U.S. 10 (1980) 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 Unite

that the requested evidence is material." Rigas, 258 F. Supp. 2d at 307 (internal citation omitted). As the Supreme Court held in United States v. Armstrong, while Rule 16 authorizes 10 EFTA00027321 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 16 of 34 defendants to exami

MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00031263 --- PAGE BREAK --- TABLE O

. 2020) 26 Standefer v. United States, 447 U.S. 10 (1980) 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 Unite

t sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462- 63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective p

lves, but rather an independent assertion that charges were brought for reasons that were improper or constitutionally invalid. See United States v. Armstrong, 517 U.S. 456, 463 (1996). Indeed, the defendant will be unable to make any kind of showing of the conspiracy theory that there was activity incons

y the provision of any investigative materials from any other U.S. Attorney's Office or other Non-Party Entities or Individuals. Very truly yours, GEOFFREY S. BERMAN By: Assistant United States Attorneys Southern District of New York Tel: EFTA00016600

de by an attorney for the government or other government agent in connection with investigating or prosecuting the case); see also United States v. Armstrong, 517 U.S. at 463 (1996) ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government work product in connection with his case."). Fourth Reque

517 U.S. at 463 ("[U]nder Rule I 6(a)(2), [a defendant] may not examine Government work product in connection with his case."). Very truly yours, GEOFFREY S. BERMAN By Assistant United States Attorneys Southern District of New York Tel: EFTA00027238