Epstein Secrets

g the subpoena must also show that the "the application is made in good faith and is not intended as a general fishing expedition." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700) (internal quotation marks omitted), abrogated on other grounds as recognized

ally to the specific requests for them, as discussed above. EFTA00010124 --- PAGE BREAK --- Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For

above. EFTA00010124 --- PAGE BREAK --- Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For the foregoing reasons, the Court should quash the

d be treated identically to the specific requests for them, as discussed above. EFTA00090229 Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For

r them, as discussed above. EFTA00090229 Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For the foregoing reasons, the Court should quash the

o, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16, 2021) (citing Bowman Data, Co., 341 U.S. at 220 (1951)); see also United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and objects to be introduced at criminal trials"),

g subpoena that "call[s] for the production of the entire investigative file and is accurately described as a fishing expedition"); United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to obtain ident ed evidence rath

o, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16, 2021) (citing Bowman Dab), Co., 341 U.S. at 220 (1951)); see also United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and objects to be introduced at criminal trials"),

g subpoena that "call[s] for the production of the entire investigative file and is accurately described as a fishing expedition"); United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to obtain ident ed evidence rath