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

8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unit

er necessary element to prevail: that the claimed delay by the Government was intentional and deliberate to gain a strategic advantage. Here, as in Lovasco, any pre-indictment delay was the result of the Government's continuing investigation of the case. The Lovasco Court held that the investigative de

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

8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite

ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t

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

8) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite

ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t

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

8) 105 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 45 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 18, 21 United States v. Lovasco, 431 U.S. 783 (1977) 52, 53, 54, 55 United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 174, 176, 177 United S

ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 53 EFTA00095145 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the

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

) 152 United States v. Long, 697 F. Supp. 651 (S.D.N.Y. 1988) 65 United States v. Lopez, 944 F.2d 33 (1st Cir. 1991) 21, 26 United States v. Lovasco, 431 U.S. 783 (1977) 76, 79, 80, 82 United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657 (S.D.N.Y. Aug. 26, 2014) 266, 268, 269 Unite

ndant could establish any actual prejudice—which she cannot—such prejudice would be "necessary but not sufficient" to establish a due process claim. Lovasco, 431 U.S. at 790. The defendant's motion fails because she has not demonstrated the other necessary element to prevail: that the claimed delay by t