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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
nna Vljua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187,198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr. (
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-
case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the
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
mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.
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-
case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the
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
mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.
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-
case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the
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
368 (S.D.N.Y. 2010) 175 United States v. Marcus, 628 F.3d 36 (2d Cir. 2010) 163 United States v. Marion, 404 U.S. 307 (1971) United States v. Markiewicz, 42, 44, 49 978 F.2d 786 (2d Cir. 1992) 120, 121, 125, 134 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 113 United States v. Martinez,
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
mma Vijua, No. 15 Cr. 240, 2016 WL 107841 (N.D. Tex. Jan. 11, 2016) 22 United States v. Marion, 404 U.S. 307 (1971) 59, 63, 72 United States v. Markiewicz, 978 F.2d 786 (2d Cir. 1992) 178, 180, 187, 198 United States v. Martin, 426 F.3d 68 (2d Cir. 2005) 167 United States v. Martinez, No. 92 Cr.
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-
case, the "answers associated with the questions posed may be insufficient as a matter of law to support the perjury conviction." United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992) (quoting Lighte, 782 F.2d at 375). For instance, in Lighte, a case involving post-conviction appellate review, the
Entities connected to both Urena and Markiewicz

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONChacko
PERSONGaudin
PERSONForde
ORGANIZATION
Medina
PERSONNejad
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Napolitano
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Supreme Court
ORGANIZATIONThompson
PERSONWerner
PERSONSampson
PERSONConcepcion
PERSONMostafa
PERSON
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATION
Adriana Ross
PERSON
Giglio
PERSON