Epstein Secrets

ed. R. Crim. P. 16(a)(1)(E). "Evidence is material if it could be used to counter the [G]overnment's case or to bolster a defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S.

and a wide range of written [BOP] policies and regulations," as well as "statements for all of the witnesses interviewed during the investigation." Gov't Opp. at 8-9, ECF No. 35. Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Proced

ed. R. Crim. P. 16(a)(1)(E). "Evidence is material if it could be used to counter the [G]overnment's case or to bolster a defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S.

and a wide range of written [BOP] policies and regulations," as well as "statements for all of the witnesses interviewed during the investigation." Gov't Opp. at 8-9, ECF No. 35. Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Proced

ed. R. Crim. P. 16(a)(1)(E). "Evidence is material if it could be used to counter the [G]overnment's case or to bolster a defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S.

and a wide range of written [BOP] policies and regulations," as well as "statements for all of the witnesses interviewed during the investigation." Gov't Opp. at 8-9, ECF No. 35. Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Proced