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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
Supp. 540 (S.D.N.Y.1996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 253 United States v. Pirro, 212 F.3d 86 (2d Cir. 2000) 229 United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL
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-
riminal trust that existed between coconspirators; and/or (iii) complete the story of the crime charged. See Diaz, 176 F.3d at 80; United States v. Pipola, 83 F.3d 556, 566 (2d Cir. 1996); United States it Rosa, 11 F.3d 315, 334 (2d Cir. 1993). In addition, evidence of "other acts" is admissible under
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
Supp. 540 (S.D.N.Y.I996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 253 United States v. Pirro, 212 F.3d 86 (2d Cir. 2000) 229 United States v. Pizarro, No. 17 Cr. 151 (MN), 2018 WL
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-
riminal trust that existed between coconspirators; and/or (iii) complete the story of the crime charged. See Diaz, 176 F.3d at 80; United States v. Pipola, 83 F.3d 556, 566 (2d Cir. 1996); United States v. Rosa, 11 F.3d 315, 334 (2d Cir. 1993). In addition, evidence of "other acts" is admissible under
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
Supp. 540 (S.D.N.Y.I996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 253 United States v. Pirro, 212 F.3d 86 (2d Cir. 2000) 229 United States v. Pizarro, No. 17 Cr. 151 (MN), 2018 WL
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-
riminal trust that existed between coconspirators; and/or (iii) complete the story of the crime charged. See Diaz, 176 F.3d at 80; United States v. Pipola, 83 F.3d 556, 566 (2d Cir. 1996); United States v. Rosa, 11 F.3d 315, 334 (2d Cir. 1993). In addition, evidence of "other acts" is admissible under
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
Supp. 540 (S.D.N.Y.I996) 189 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 166 United States v. Pino, 212 F.3d 86 (2d Cir. 2000) 151 United States v. Pizarro, No. 17 Cr. 151 (MN), 2018 WL 1
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
Supp. 540 (S.D.N.Y.I996) 281 United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140 (S.D.N.Y. Aug. 9, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 253 United States v. Pbro, 212 F.3d 86 (2d Cir. 2000) 229 United States v. Pizarro, No. 17 Cr. 151 (MN), 2018 WL 1
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-
riminal trust that existed between coconspirators; and/or (iii) complete the story of the crime charged. See Diaz, 176 F.3d at 80; United States v. Pipola, 83 F.3d 556, 566 (2d Cir. 1996); United States v. Rosa, 11 F.3d 315, 334 (2d Cir. 1993). In addition, evidence of "other acts" is admissible under
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