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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
RPP), 201 1 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)
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-
f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to 'other crimes, wrongs, or ads' evidence, under which
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
(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)
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-
of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which
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
(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)
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-
of the alleged conspiracy . is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which
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
(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 105, 109, 111 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 186 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 165 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 182 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)
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
(RPP), 2011 WL 3738969 (S.D.N.Y. Aug. 22, 2011) 153, 160, 163 United States v. Collins, 409 F. Supp. 3d 228 (S.D.N.Y. 2019) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014)
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-
f the alleged conspiracy ... is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Second Circuit "follows the `inclusionary' approach to `other crimes, wrongs, or acts' evidence, under which
Entities connected to both Urena and Concepcion

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATIONChacko
PERSONThompson
PERSONWerner
PERSON
Napolitano
PERSONNejad
PERSONSampson
PERSONMarkiewicz
PERSONGaudin
PERSONForde
ORGANIZATION
Medina
PERSON
Adriana Ross
PERSONthe Southern District
LOCATIONMostafa
PERSONFBI
ORGANIZATION