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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
e, 456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Mt1 Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Ha. 2012) 23,24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98 Cr. (KIK), 1999 WL 9848 (S.D.N.Y. Jan. 11, 1999) 275,281 United Stat
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-
at 1269 (appeal following conviction and partial Rule 29 dismissal) Markiewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 23, 24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98 Cr. (JGK), 1999 WL 9848 (S.D.N.Y. Jan. II, 1999) 275, 281 United Sta
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-
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 23, 24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98 Cr. (JGK), 1999 WL 9848 (S.D.N.Y. Jan. II, 1999) 275, 281 United Sta
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-
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
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
456 F.2d 46 (4th Cir. 1972) 201 United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 19, 20 United States v. Forde, 740 F.Supp.2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98 Cr. (JGK), 1999 WL 9848 (S.D.N.Y. Jan. II, 1999) 183, 189 United State
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
456 F.2d 46 (4th Cir. 1972) 293 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 23, 24 United States v. Forde, 740 F. Supp. 2d 406 (S.D.N.Y. 2010) passim United States v. Gallo, No. 98 Cr. (JGK), 1999 WL 9848 (S.D.N.Y. Jan. II, 1999) 275, 281 United Sta
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-
at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United States v. Forde, 740 F. Supp. 2d 406, 413 (S.D.N.Y. 2010) (denying a motion to dismiss a perjury count). Indeed, the defendant cites no case in which a court has di
Entities connected to both Urena and Forde

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSampson
PERSONWerner
PERSONChacko
PERSONNejad
PERSON
Supreme Court
ORGANIZATIONGaudin
PERSONMarkiewicz
PERSONThompson
PERSON
Napolitano
PERSON
Medina
PERSONConcepcion
PERSON
Scarlett Johansson
PERSONMostafa
PERSON
Adriana Ross
PERSONthe Southern District
LOCATION
Southern District of New York
ORGANIZATION
Giglio
PERSON