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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
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
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
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
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
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
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
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
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
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
56, (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 United States v. Bass, 536 U.S. 862 (2002) 30, 33 United States v. Berrios, 501 F.2d 1207 (2d Cir. 1974) 30,
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 Barcelo and Middendorf

Jeffrey Epstein
PERSON
United States
LOCATION
Brady
PERSONFinnerty
PERSONCollins
PERSONFBI
ORGANIZATION
Giglio
PERSONAvellino
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Martha Stewart
PERSONGhailani
PERSON
Southern District of New York
ORGANIZATIONLocascio
PERSON
Alfredo Rodriguez
PERSON
New York Stock Exchange
ORGANIZATION
Department of Justice
ORGANIZATIONthe Department of Justice's Office of Professional Responsibility
ORGANIZATION
Prince Andrew
PERSONthe Securities and Exchange Commission
ORGANIZATION