Epstein Secrets

on" to fire him. CNN <https://www.cnntotn/2020/11/11/politics/trump-russia-investigation-declassification-battle/index.html> (11/11, Cohen, Gangel, Perez, 83.I6M) reports that concerns over declassification "roared back this week in the wake of a flurry of personnel changes at the National Security Ag

adults in many areas of the country." The New York Times <hftps://wwvv.nytimes.corn/2020/11/11/nyregion/nj-newark-coronavirus-curfew.html> (11/11, Armstrong, Tully, 18.61M) reports that in Newark "over the last four days, there have been 842 new reported infections, and 19 percent of people tested over t

former Defense Secretary Esper's support for Nakasone "may have played a role in Trump's surprise decision" to fire him. CNN (11/11, Cohen, Gangel, Perez, 83.16M) reports that concerns over declassification "roared back this week in the wake of a flurry of personnel changes at the National Security A

go all remote next week as infection rates in children are now outpacing those of adults in many areas of the country." The New York Times (11/11, Armstrong, Tully, 18.61M) reports that in Newark "over the last four days, there have been 842 new reported infections, and 19 percent of people tested over

former Defense Secretary Esper's support for Nakasone "may have played a role in Trump's surprise decision" to fire him. CNN (11/11, Cohen, Gangel, Perez, 83.16M) reports that concerns over declassification "roared back this week in the wake of a flurry of personnel changes at the National Security A

go all remote next week as infection rates in children are now outpacing those of adults in many areas of the country." The New York Times (11/11, Armstrong, Tully, 18.61M) reports that in Newark "over the last four days, there have been 842 new reported infections, and 19 percent of people tested over

r. 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. 1998) 19, 25 United States v. Bagley, 473 U.S. 667 (1985) 7 Unite

d 04/24/20 Page 5 of 34 United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S

that the requested evidence is material." Rigas, 258 F. Supp. 2d at 307 (internal citation omitted). As the Supreme Court held in United States v. Armstrong, while Rule 16 authorizes 10 EFTA00027321 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 16 of 34 defendants to exami

. 2020) 26 Standefer v. United States, 447 U.S. 10 (1980) 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 Unite

66 --- PAGE BREAK --- United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United States v. Persico, 645 F.3d 85 (2d Cir. 2011) 8 21 10 8 United States v. Reese, 933 F. Supp. 2d 579 (S

t sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462- 63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective p