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on of maintaining a set of statutes that reflect, rather than distort, the policy choices that elected representatives have made." C • OAlmendarez- Torres v. United States, 523 U.S. 224, 237-38,118 S. Ct. 1219, 1277-28, 140 L.Ed.2d 350 (1998). To that end, the Supreme Court has cautioned that, "rewrit
U.S. 33, 39, 117 S. Ct. 417, 421, 136 L.Ed.2d 347 (1996) ("We have long held that the 'touchstone of the Fourth Amendment is reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S.
e general nature of certain portions of the Indictment does "not advise [Mr. Epstein] of the specific acts of which he is accused." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990). See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154
cluding Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all mater
e general nature of certain portions of the Indictment does "not advise [Mr. Epstein] of the specific acts of which he is accused." United States v. Torres, 901 F.2d 205, 234 (2d Cir. 1990). See also United States v. Rigas, 490 F.3d 208, 237 (2d Cir. 2007); United States v. Davidoff 845 F.2d 1151, 1154
Page: EFTA00016141 →cluding Giglio v. United States, 405 U.S. 150 (1972), United States v. Agurs, 427 U.S. 97 (1976), United States v. Bagley, 473 U.S. 667 (1985), and Kyles v. Whitney, 514 U.S. 419 (1995), and Judge Berman's Individual Practices, Mr. Epstein requests immediate identification and disclosure of all mater
Page: EFTA00016142 →Entities connected to both Torres and Kyles

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
George W. Bush
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Brady
PERSONFBI
ORGANIZATIONCollins
PERSONPerez
PERSON
Alfredo Rodriguez
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
Louisiana
LOCATION
Giglio
PERSON
Geoffrey S. Berman
PERSON