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including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). In considering whether Rule 16 and Brady
U.S. Department of Justice United States Attorney Southern District of New York Tht Sill Ill .1 Molt, Budding October 7, 2020 VIA ECF The Honorable Alison J. Nathan Unit
States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros
including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). In considering whether Rule 16 and Brady
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,
States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros
including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). In considering whether Rule 16 and Brady
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,
States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros
including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). In considering whether Rule 16 and Brady
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,
States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros
including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). In considering whether Rule 16 and Brady
Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 1 of 8 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York. New York 10007 October 7, 20
States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros
Entities connected to both Barcelo and Department of Justice

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSONFederal Bureau of Prisons
ORGANIZATION
Geoffrey S. Berman
PERSON
Southern District of New York
ORGANIZATION
Alfredo Rodriguez
PERSON
Audrey Strauss
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Paul Ryan
PERSON
Bernie Sanders
PERSONCollins
PERSONThe Silvio J. Mollo Building
ORGANIZATION
Ronald Reagan
PERSON
Martha Stewart
PERSONSecond Circuit
ORGANIZATIONthe Securities and Exchange Commission
ORGANIZATION