Epstein Secrets

rcement agency, any BOP records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Righ

cally, BOP contends that it cannot produce the SHU log books showing when prison staff did rounds on certain days because they "were handed over to the Office of the Inspector General (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of N

rcement agency, any BOP records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Righ

cally, BOP contends that it cannot produce the SHU log books showing when prison staff did rounds on certain days because they "were handed over to the Office of the Inspector General (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of N

described below. At the initial pretrial conference on November 11, 2019, Thomas, through counsel, raised the issue of an "ongoing . . . report" by the Office of the Inspector General and requested the "status" of the report and when it would be completed.4 (Conf. Tr., Nov. 25, 2019, at 3-4, 7-9). In response, the Government expl

oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Biyan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out

described below. At the initial pretrial conference on November 11, 2019, Thomas, through counsel, raised the issue of an "ongoing . . . report" by the Office of the Inspector General and requested the "status" of the report and when it would be completed.4 (Conf. Tr., Nov. 25, 2019, at 3-4, 7-9). In response, the Government expl

oyees who have at other times also allegedly falsified records. The cases Thomas cites do not support a contrary result. In United States v. Bryan, the Ninth Circuit concluded that the government could not limit its discovery obligations to documents located in the district of prosecution since the case came out