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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
67,68,71 United States v. Scarpa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scarpa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 121 xxi EFTA00099962 United States v. Schalk-id-, 871 F.2d 300 (2d Cir. 1989) 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-
Contrary to the defendant's claims (Def. Mot. 11 at 10), she assumed the risk that the would divulged to the Government. See, e.g.,United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17. 2019) 121 xxi EFTA00077627 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 182
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-
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
67, 68, 71 United States v. Scaipa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17. 2019) 121 xxi EFTA00039442 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 182
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-
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
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
nited States v. Scaipa, 913 F.2d 993 (2d Cir. 1990) 159, 160, 162, 164 United States v. Scaipa, 913 F.3d 993 (2d Cir. 1990) 42 United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 86 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 121 United States v. Sch
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
, 68, 71 United States v. Scam pa, 897 F.2d 63 (2d Cir. 1990) 69 United States v. Scam pa, 913 F.2d 993 (2d Cir. 1990) passim United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 121 xxi EFTA00103020 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 18
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-
nt's claims (Def. Mot. 11 at 10), she assumed the risk that the deposition transcripts would divulged to the Government. See, e.g., United States v. Schaefer, No. 17 Cr. 400 (HZ), 2019 WL 267711, at *5 (D. Or. Jan. 17, 2019) (declining to apply Carpenter where government obtained defendant's eBay transac
Entities connected to both Urena and Schaefer

Jeffrey Epstein
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Ghislaine Maxwell
PERSONMartin Weinberg
PERSONthe Southern District
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Julie K. Brown
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George Mitchell
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Scarlett Johansson
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Oregon
LOCATIONAshburn
LOCATIONBryson v. United States
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