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Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 15 of 38 government agencies because it is highly relevant to Mr. Thomas’ defense in this case. Furthermore, the government had Mr. Thomas sign a consent form specifically from the Inspector General’s office. (See Exhibit C.) Thereafter, the government tumed over the results of this search in the normal course of discovery production. This fact shows that the Inspector General was investigating this incident thus all information they receive is discoverable. This Court should order the production of the documents within forty-five (45) days from the entry of an order on this motion. B. Rule 16 and Brady-Giglio Include the Production of Documents and — Reports Generated by Other Agencies The facts, shown above as reported in the media and secondary sources, clearly show that other agencies were involved in the investigation of Jeffrey Epstein’s death and the defendant’s arrest and indictment. Thus, clearly, this Court should not permit the government to selflimit discovery. A prosecutor is not "allowed to avoid disclosure of evidence by the simple expedient of leaving relevant evidence to repose in the hands of another agency while utilizing his access to it in preparing his case for trial." United States v. Trevino, 556 F.2d 1265, 1272 (5th Cir.1977); U.S. v. Giffen, 379 F. Supp. 2d 337 (S.D. N.Y. 2004) In United States v. Bryan, 868 F.2d 1032 (9th Cir.1989), cert. denied, 493 U.S. 858, 110 S.Ct. 167, 107 L.Ed.2d 124 (1989), after a nationwide investigation by the IRS, Bryan had been convicted of, among other things, conspiracy to defraud the United States. Bryan sought discovery, under Rule 16(a)(1)(C) of items that were in the possession of the FBI. The charges against Bryan stemmed from the IRS investigation, and this difference, together with the further objection that production should be limited only to documents found in the District in which the matter was pending, Oregon, formed the basis of the government’s objection. 11 DOJ-OGR- 00022038