Epstein Secrets

defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S. Ct. 2206 (2018). "In order to compel the Government to produce certain evidence, a defendant must make a prima facie showin

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

96 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (1989) 159 Carpenter v. United States, 138 S. Ct. 2206 passim Chambers v. Mississippi, 410 U.S. 284 (1973) 159 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D.

e aprima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

basic purpose of this Amendment ... is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials." Carpenter v. United States, 138 S. Ct. 2206, 2213 (internal quotation marks and citation omitted). "It has been clear for a generation that 'Fourth Amendment

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

96 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (1989) 159 Carpenter v. United States, 138 S. Ct. 2206 passim Chambers v. Mississippi, 410 U.S. 284 (1973) 159 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D.

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

basic purpose of this Amendment ... is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials." Carpenter v. United States, 138 S. Ct. 2206, 2213 (internal quotation marks and citation omitted). "It has been clear for a generation that `Fourth Amendment

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

96 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (1989) 159 Carpenter v. United States, 138 S. Ct. 2206 passim Chambers v. Mississippi, 410 U.S. 284 (1973) 159 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D.

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

basic purpose of this Amendment ... is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials." Carpenter v. United States, 138 S. Ct. 2206, 2213 (internal quotation marks and citation omitted). "It has been clear for a generation that `Fourth Amendment

Rule 16 of making "a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-

96 U.S. 64 (1969) 101 Burgess v. United States, 552 U.S. 124 (2008) 37 Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (1989) 108 Carpenter v. United States, 138 S. Ct. 2206 82, 83, 84, 85 Chambers v. Mississippi, 410 U.S. 284 (1973) 109 Chemical Bank v. Affiliated FM Ins. Co., 154

e a prima fade showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

96 U.S. 64 (1969) 147 Burgess v. United States, 552 U.S. 124 (2008) 51 Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (1989) 159 Carpenter v. United States, 138 S. Ct. 2206 passim Chambers v. Mississippi, 410 U.S. 284 (1973) 159 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D.

a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (citations omitted). Here, the defendant has offered nothing more than her conjecture that some unspecifie

asic purpose of this Amendment . . . is to safeguard the privacy and security of individuals against arbitrary invasions by governmental officials." Carpenter v. United States, 138 S. Ct. 2206, 2213 (internal quotation marks and citation omitted). "It has been clear for a generation that `Fourth Amendment

ule 16 of making "a prima facie showing of materiality and must offer more than the conclusory allegation that the requested evidence is material." Urena, 989 F. Supp. 2d at 261 (citations omitted). Because the defendant has offered nothing more than her conjecture, based on an inaccurate and hearsay-