Epstein Secrets

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the gov

Y investigation into this case (see Dkt. 63), or at any time thereafter. 15. We request the complete FBI's case file regarding the investigation of Alfredo Rodriguez for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. 16. We request copies of the "82-page pros m

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

write a statute as it pleases." It • Jennings v. Rodriguez, 538 U.S. -, 138 S. Ct. 830, 843-44, 200 L.Ed.2

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.

22 specific requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, incl

be produced "in sufficient time that the defendant will have a reasonable opportunity to act upon the information efficaciously." United States v. Rodriguez, 496 F.3d 221, 226 (2d Cir. 2007). Immediate disclosure of such material is not warranted simply because the defendant prefers it. See, e.g., United