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Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 26 of 34 2d 1, 9 (D.D.C. 2006), required the prosecutors to obtain records from the Office of the Vice President and the Central Intelligence Agency, even though those parts of government did not participate in the grand jury investigation, that holding was an outlier, which has never been cited by another court, and the decision itself has never been cited in this Circuit. Finally, even if such materials had any conceivable relevance to the charges at hand (which, as discussed above, they do not), asking the Government to conduct a broad canvassing of the BOP’s records—including searching databases located out of state, reviewing large quantities of documents, attempting to pull archived records going back as far as 2005, and parsing through attorney work product—would be inordinately time consuming and burdensome for attorneys for the Government, which does not have custody of the files, is not familiar with the files, and knows of no effective way to search them. It would, as the Circuit warned against in Avellino, “condemn the prosecution of criminal cases to a state of paralysis.” 136 F.3d at 255. Such a result is not legally required by Rule 16, Brady, or Giglio, and therefore Thomas’s motion should be denied. D. Any Draft Inspector General Report is Not Subject to Disclosure Thomas argues that any report by the Inspector General and related materials must be produced because he speculates that such a report will address systemic issues at the BOP, including purported staffing shortages at the MCC. (Mot. 5, 9-10). For the reasons set forth above, any draft Inspector General Report is not discoverable because the issues Thomas believes it will discuss are not material to the preparation of a valid defense, see Part II.B, and the draft reports, to the extent they exist, are protected from disclosure by the deliberative process privilege. While the prosecution team has had no involvement in writing the Inspector General Report, the Government understands that those attorneys from DOJ-OIG responsible for writing the Report have not yet completed a draft, and do not anticipate completing the Report in the near term. As 21 DOJ-OGR- 00022088