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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
to reviewing such evidence only where the Government conducts a loint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-.5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Overs
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
o reviewing such evidence only where the Government conducts a "joint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversi
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
o reviewing such evidence only where the Government conducts a "joint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversi
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
o reviewing such evidence only where the Government conducts a "joint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at ■4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversi
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
o reviewing such evidence only where the Government conducts a "joint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversi
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
dy material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at '4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A
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
dy material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at '4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A
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
dy material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at '4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A
dy material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at *4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A
Page: EFTA00022189 →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 →0) 13 United States v. Alamelz, 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: EFTA00031265 →4 United States v. Manzano, 945 F.3d 616 (2d Cir. 2019) 13, 17 United States v. McGuinness, 764 F. Supp. 888 (S.D.N.Y. 1991) 11 United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at *4-5 (S.D.N.Y. Aug. 17, 2018) 20, 22 United States v. Moon, 718 F.2d 1210 (2d Cir. 1983) 30, 33 iii E
Page: EFTA00031266 →Entities connected to both Avellino and Middendorf

Jeffrey Epstein
PERSON
United States
LOCATION
Brady
PERSONCollins
PERSONFinnerty
PERSON
Giglio
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Martha Stewart
PERSONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONLocascio
PERSON
Alfredo Rodriguez
PERSONBarcelo
PERSONGhailani
PERSON
New York Stock Exchange
ORGANIZATION
Prince Andrew
PERSON
Armstrong
PERSONCoppa
PERSONBlaszczak
PERSON