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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-
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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-
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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-
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[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
4 (2d Cir. 1965) 101 United States v. Wong, 431 U.S. 174 (1977) 101 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 43 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 139 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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
4 (2d Cir. 1965) 146 United States v. Wong, 431 U.S. 174 (1977) 146 United States v. Wright, 343 F.3d 849 (6th Cir. 2003) 62 United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139 (E.D.N.Y. Oct. 19, 2018) 206 United States v. Yonkers Contracting Co., Inc., 682 F. Supp. 757 (S.D.N.Y. 19
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-
(quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, "[t
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