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e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
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-
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
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-
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
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-
e defense attorneys' alleged efforts to "pique" the Government's interest "in a second meeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020,
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-
Entities connected to both Stephen Rex Brown and Urena

Jeffrey Epstein
PERSON
Stephen Hawking
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
David Boies
PERSONColleen McMahon
PERSONJeffrey Pagliuca
PERSON
Southern District of New York
ORGANIZATION
Bradley Edwards
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
North Carolina
LOCATIONJane Doe
PERSON
United States
LOCATION
Michael Cohen
PERSON
Supreme Court
ORGANIZATION
George W. Bush
PERSONMartindell
PERSON
Carpenter
PERSON