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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 →the extent it should be produced, that production is governed by Rule 16, Rule 26.2, Brady, and Giglio, but not Rule 17. See, e.g., United States v. Carton, 17 Cr. 680 (CM), 2018 WL 5818107, at *4 (S.D.N.Y. Oct. 19, 2018) (rejecting a request for a personnel file because the BSF, Dkt. No. 191 at 5 ("Th
Page: EFTA00015870 →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
the extent it should be produced, that production is governed by Rule 16, Rule 26.2, Brady, and Giglio, but not Rule 17. See, e.g., United States v. Carton, 17 Cr. 680 (CM), 2018 WL 5818107, at *4 (S.D.N.Y. Oct. 19, 2018) (rejecting a request for a personnel file because the BSF, Dkt. No. 191 at 5 ("Th
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Entities connected to both Barneys New York and Carton

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Chris Tucker
PERSONFBI
ORGANIZATION
Michael Cohen
PERSONMaria Farmer
PERSON
Marc Rich
PERSON
Lawrence Krauss
PERSON
Cynthia Nixon
PERSON
Xi Jinping
PERSON
Audrey Strauss
PERSON
David Boies
PERSON
Giglio
PERSONSkelos
PERSON
Brady
PERSONSouthern District
LOCATIONSecond Circuit
ORGANIZATION