“functional equivalent” of express questioning. United States v. Stroman, 420 Fed.Appx. 100, 103 (2d Cir.2011) (noting that “[s]everal courts have asserted that, under certain circumstances, showing evidence to the defendant may be the functional equivalent of custodial interrogation” but declining to determine whether showing video to defendant and directing him to be quiet constituted a Miranda violation) (citations omitted). There is no indication that Officer Reyes should have known her statement, pointing out that the currency was counterfeit, was likely to elicit an incriminating response from Defendant. As a preliminary matter, Officer Reyes’s inventory of Defendant’s belongings was not, in itself, the functional equivalent of interrogation. See Broughton, 983 F.Supp.2d at 232 (<HOLDING>). Furthermore, there is nothing in the record
holding that an interrogation occurs when there is express questioning or any words or actions on the part of the police other than those normally attendant to arrest and custody that the police should know are reasonably likely to elicit an incriminating response from the suspect holding that defendants inculpatory statements were not the product of interrogation where a detective could not have known his words would elicit an incriminating response holding that a defendants response to a question about his address was not protected by miranda notwithstanding the fact that pohce made use of the statement because it was not intended to elicit incriminating statements holding that a comment made by one police officer to another in the presence of the accused expressing concern that handicapped children might come across a shotgun is not a statement designed to elicit an incriminating response holding that examining defendants luggage for contraband in front of her was not the type of activity that was likely to elicit an incriminating response  citation omitted