Epstein Secrets

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

McCourty, 562 F.3d 458 (2d Cir. 2009) 260 xvii EFTA00099958 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 257 United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917 (S.D.N.Y. July 7, 2014) 261 United States v. Miller, 116 F.3d 641 (2d Cir. 1997) 252, 292 United States

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-

ourts in this Circuit have routinely denied pre- trial motions to dismiss potentially multiplicitous counts as premature." (quoting United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014))); United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703, at *I (S.D

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

McCourty, 562 F.3d 458 (2d Cir. 2009) 260 xvii EFTA00077623 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 257 United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917 (S.D.N.Y. July 7, 2014) 261 United States v. Miller, 116 F.3d 641 (2d Cir. 1997) 252, 292 United States

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-

ourts in this Circuit have routinely denied pre- trial motions to dismiss potentially multiplicitous counts as premature." (quoting United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014)1); United States v. Dwnitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703, at *1 (S.D

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

McCourty, 562 F.3d 458 (2d Cir. 2009) 260 xvii EFTA00039438 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 257 United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917 (S.D.N.Y. July 7, 2014) 261 United States v. Miller, 116 F.3d 641 (2d Cir. 1997) 252, 292 United States

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-

ourts in this Circuit have routinely denied pre- trial motions to dismiss potentially multiplicitous counts as premature." (quoting United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014)1); United States v. Dwnitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703, at *1 (S.D

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

100 United States v. McCourty, 562 F.3d 458 (2d Cir. 2009) 170 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 168 United States v. Medina, 13 Cr. 272 (PGG), 2014 WL 3057917 (S.D.N.Y. July 7, 2014) 170 United States v. Miller, 116 F.3d 641 (2d Cir. 1997) 165, 200 United States v. M

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

McCourty, 562 F.3d 458 (2d Cir. 2009) 260 xvii EFTA00103016 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 257 United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917 (S.D.N.Y. July 7, 2014) 261 United States v. Miller, 116 F.3d 641 (2d Cir. 1997) 252, 292 United States

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-

ourts in this Circuit have routinely denied pre- trial motions to dismiss potentially multiplicitous counts as premature." (quoting United States v. Medina, No. 13 Cr. 272 (PGG), 2014 WL 3057917, at *3 (S.D.N.Y. July 7, 2014))); United States v. Dumitru, No. 18 Cr. 243 (LAK), 2018 WL 3407703, at *1 (S.D