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oyed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
yed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer t
iately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to
here the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought wer
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
y, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession nec
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
y, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession nec
members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
y, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession nec
y, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession nec
Page: EFTA00022188 →members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIE
Page: EFTA00022193 →80) 13 United States v. Alameh, 341 F.3d 167 (2d Cir. 2003) 29, 30, 31 United States v. Armstrong, 517 U.S. 456, (1996) passim United States v. Avellino, 136 F.3d 249 (2d Cir. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 United States v. Barcelo, 628 F. App'x 36 (2d Cir. 2015) 19
Page: EFTA00027309 →13 United States v. Fares, 978 F.2d 52 (2d Cir. 1992) 30, 31, 33 United States v. Fernandez, 231 F.3d 1240 (9th Cir. 2000) 26 United States v. Finnerty, 411 F. Supp. 2d 428 (S.D.N.Y. 2006) 20 United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) 16 United S
Page: EFTA00027310 →Entities connected to both Avellino and Finnerty

Jeffrey Epstein
PERSON
United States
LOCATION
Brady
PERSONCollins
PERSON
Giglio
PERSONMiddendorf
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Martha Stewart
PERSONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONBarcelo
PERSONGhailani
PERSONLocascio
PERSON
Alfredo Rodriguez
PERSON
Armstrong
PERSONCoppa
PERSONBlaszczak
PERSON
New York Stock Exchange
ORGANIZATIONQuinn
PERSON