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a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
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 Proced
a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
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 Proced
a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosu
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 Proced
Entities connected to both Abdalla and Gov't Opp

Armstrong
PERSON
Jeffrey Epstein
PERSON
Giglio
PERSON
United States
LOCATION
Rivera
PERSONCoppa
PERSONGoode
PERSONUlbricht
PERSON
Metropolitan Correctional Center
ORGANIZATIONSpecial Housing Unit
ORGANIZATIONAvellino
PERSONBlaszczak
PERSONFinnerty
PERSONMinaya
PERSONMiddendorf
PERSONJuliano
PERSONMerlin
PERSONThe Clerk of Court
ORGANIZATION
Southern District of New York
ORGANIZATIONTOVA NOEL
PERSON