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Case 1:19-cr-00830-AT Document 36 Filed 06/09/20 Page2of9 Prisons (the “BOP”)] as to both [D]efendants, including[] any and all supporting memorandums, written statements, photos, videos, and incident reports,” id. at 6; and (3) “any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured, or possessed by any investigative or disciplinary agencies[] participating in the investigation of the [D]efendants, allied with the prosecution, and to which the prosecution has access,” id. at 7. For the reasons stated below, Thomas’ motion is DENIED. DISCUSSION The Government has already produced “surveillance video going back to July 5, 2019...; count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein’s suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written [BOP] policies and regulations,” as well as “statements for all of the witnesses interviewed during the investigation.” Gov’t Opp. at 8-9, ECF No. 35. Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court’s decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires the Government to “permit the defendant to inspect and to copy or photograph books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items, if the item is within the government’s possession, DOJ-OGR- 00022098