Epstein Secrets

. BACKGROUND On June 29, 2020, a grand July sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBI") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

, some version of the phrase "deliberate device" and "tactical advantage" is found in nearly every Second Circuit decision on the issue. See, e.g., Alameh, 341 F.3d at 176 ("intentionally used delay to gain unfair tactical advantage"); Cornielle, 171 F.3d at 752 (requiring "intentional device" to gain

Council v. United States Ening. Prot. Agency, 954 F.3d 150 (2d Cir. 2020) 26 Standefer v. United States, 447 U.S. 10 (1980) 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.

e round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation.2 Subsequently, the Government made three additional discovery productions, much

te not only (1) "had a discriminatory effect" but was also (2) "motivated by a discriminatory purpose." Armstrong, 517 U.S. at 465; United States v. Alameh, 341 F.3d 167, 173 (2d Cir. 2003); United States v. Fares, 978 F.2d 52, 59 (2d Cir. 1992); United States v. Moon, 718 F.2d 1210, 1229 (2d Cir. 1983

e round reports; MCC phone records; personnel records and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation? Subsequently, the Government made three additional discovery productions, much

te not only (1) "had a discriminatory effect" but was also (2) "motivated by a discriminatory purpose." Armstrong, 517 U.S. at 465; United States v. Alameh, 341 F.3d 167, 173 (2d Cir. 2003); United States v. Fares, 978 F.2d 52, 59 (2d Cir. 1992); United States v. Moon, 718 F.2d 1210, 1229 (2d Cir. 1983