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pecify the information contained or believed to be contained in the documents sought rather than merely hop[e] that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 50868
ed as 'a discovery device,' but instead should be used only as 'a mechanism for obtaining specific admissible evidence.'" (quoting United States v. Barnes, No. 04 Cr. 186 (SCR), 2008 WL 9359654, at *4 (S.D.N.Y. Apr. 2, 2008)). "Conclusory statements," like the defendant's here, are "insufficient to sat
al without such production,' and that `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), abrogated on other grounds as recognized by United States v. Chambers, 751 F.
victims to speak to law enforcement. CNN (05/11, Cohen), Washington Post (05/11, Harris), Washington Examiner (05/11, Bide), New York Times (05/11, Barnes), NBC News (05/11, Luce), and Reuters (05/11, Landay) also reported on the story. Migrant Influx Overwhelms Southern Border as Title 42 Winds Down
ngson faces up to life in prison for allegedly dealing cocaine, LSD, and marijuana on the online marketplace. The article EFTA00160381 added that Ulbricht, who was sentenced to life in prison in 2015, has repeatedly insisted that he is innocent. Silk Road was seized and shut down by the FBI in 2013. A
favored and strongly suggested that the absolute disparity theory is generally appropriate, see Rioux, 97 F.3d at 655-56; see also United States v. Barnes, 520 F. Supp. 2d 510,514 (S.D.N.Y.2007) ("Mlle absolute disparity approach is the primary approach used in this Circuit."). The "absolute disparity
ly 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 c
ted States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Barlow, 732 F. Supp. 2d 1 (E.D.N.Y. 2010) 207, 208, 210 United States v. Barnes, 520 F. Supp. 2d 510 (S.D.N.Y. 2007) 207 United States v. Batchelder, 442 U.S. 114 (1979) 173 United States v. Bejasa, 904 F.2d 137 (2d Cir. 1
rael, 05 Cr. 1039 (CM) 194 United States v. Reeves, et aL, 16 Cr. 372 (VEC) 194 United States v. Serrano, No., 13 Cr. 58 88 United States v. Ulbricht, No., 14 Cr. 68 83 United States v. Vickers, 13 Cr. 128 154 United States v. Wedd, 15 Cr. 616 179 xxv EFTA00095092 UNITED STATES DISTRICT
favored and strongly suggested that the absolute disparity theory is generally appropriate, see Rioux, 97 F.3d at 655-56; see also United States v. Barnes, 520 F. Supp. 2d 510, 514 (S.D.N.Y. 2007) ("[T]he absolute disparity approach is the primary approach used in this Circuit."). The "absolute dispar
fore trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Levin, 15 Cr. 101 (KBF); 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 c
al without such production,' and that `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), abrogated on other grounds as recognized by United States v. Chambers, 751 F.
Page: EFTA00015866 →ed as 'a discovery device,' but instead should be used only as 'a mechanism for obtaining specific admissible evidence.'" (quoting United States v. Barnes, No. 04 Cr. 186 (SCR), 2008 WL 9359654, at *4 (S.D.N.Y. Apr. 2, 2008)). "Conclusory statements," like the defendant's here, are "insufficient to sat
Page: EFTA00015869 →pecify the information contained or believed to be contained in the documents sought rather than merely hop[e] that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 50868
Page: EFTA00015870 →Entities connected to both Barneys New York and Ulbricht

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Michael Jackson
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Prince Charles
PERSON
Bloomberg L.P.
ORGANIZATIONEmmy Taylor
PERSON
George W. Bush
PERSON
George Mitchell
PERSON
John F. Kennedy
PERSON
Colorado
LOCATIONThe New York Post
ORGANIZATION