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lves, but rather an independent assertion that charges were brought for reasons that were improper or constitutionally invalid. See United States v. Armstrong, 517 U.S. 456, 463 (1996). Indeed, the defendant will be unable to make any kind of showing of the conspiracy theory that there was activity incons
Page: EFTA00016597 →sory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the production of certain docume
Page: EFTA00016597 →pretrial disclosure of the disputed evidence would enable the defendant significantly to alter the quantum of proof in his favor." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (internal quotation marks, citation, and alterations omitted). Evidence is "within the [G]ovemment's poss
Page: EFTA00022188 →selective prosecution defense, he has not met the "rigorous" standard that applies for obtaining discovery in aid of such a claim. United States v. Armstrong, 517 U.S. 456, 468 (1996). "[A] defendant who seeks discovery on a claim of selective prosecution must show some evidence of both discriminatory ef
Page: EFTA00022194 →sory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the production of certain docume
Page: EFTA00027235 →de by an attorney for the government or other government agent in connection with investigating or prosecuting the case); see also United States v. Armstrong, 517 U.S. at 463 (1996) ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government work product in connection with his case."). Fourth Reque
Page: EFTA00027236 →Entities connected to both Armstrong and Urena

Jeffrey Epstein
PERSON
United States
LOCATION
Scarlett Johansson
PERSONJane Doe
PERSON
Supreme Court
ORGANIZATION
Michael Jackson
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION
Ghislaine Maxwell
PERSON
Michigan
LOCATIONEmmy Taylor
PERSON
Anderson
PERSONFBI
ORGANIZATION