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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-
ury is best equipped 119 EFTA00100086 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287,307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude,
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
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-
ury is best equipped 119 EFTA00077751 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
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-
ury is best equipped 119 EFTA00039566 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
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-
ury is best equipped 119 EFTA00103144 to determine the meaning that a defendant assigns to a specific question." Id.; see, e.g. United States v. Sampson, 898 F.3d 287, 307 (2d Cir. 2018).47 A narrow exception arises when language in a question is so "fundamentally ambiguous" that a Court can conclude
14(a). "[I]n order to prevail" on a Rule 14 motion, "the defendant must show not simply some prejudice but substantial prejudice." United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004) (quoting Werner, 620 F.2d at 928). The defendant carries this "heavy burden" because Rule 8(a) already strikes a "
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
5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cr. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cr. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir.
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
5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir
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
5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir
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
A00095086 United States v. Salerno, 481 U.S. 739 (1987) 104 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 163, 164 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 140 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 135, 136 United States v. Sampson, 898 F.3d 287 (2d Cir
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
5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) 247, 249 United States v. Sampson, 385 F.3d 183 (2d Cir. 2004) 208 United States v. Sampson, 898 F.3d 270 (2d Cir. 2018) 200, 201 United States v. Sampson, 898 F.3d 287 (2d Cir
Entities connected to both Urena and Sampson

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONThompson
PERSON
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSONWerner
PERSONChacko
PERSON
Medina
PERSON
Napolitano
PERSONNejad
PERSONMarkiewicz
PERSONGaudin
PERSONForde
ORGANIZATIONConcepcion
PERSONthe Southern District
LOCATIONMostafa
PERSONEmmy Taylor
PERSON
Adriana Ross
PERSON
Southern District of New York
ORGANIZATION