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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-
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
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-
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
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-
er the protective order was improvidently granted or whether the government had made a showing of exceptional circumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification of protective orders where district court did not make an "express finding" of improvidenc
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
ssued a "subpoena for the production of documents as part of an ongoing investigation." (Id. at 25). In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martindell, reversed the district court's decision granting the state Attorney General's motion to intervene to
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-
allows a protective order to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N.Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial
Parties' reliance."). 79 EFTA00100046 cau PPIal (Id. washy a granrad issulaubeaurnalMI an In support of her argument, the defendant cites Palmieri where the Second Circuit, applying Martind ell, reversed the district court's decision granting the state Attorney General's motion to intervene to
her the protective order was improvidently granted or whether the government had made a showing of exceptionalcircumstances or a compelling need"); Palmieri, 779 F.2d at 862 (reversing district court's modification o fprotective orders where district court did not make an "express finding" of improvidenc
Entities connected to both Urena and Palmieri v. State

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONMartin Weinberg
PERSONJane Doe
PERSON
David Boies
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Eric Schmidt
PERSONMartindell
PERSONMaria Farmer
PERSON
Rivera
PERSON
Michael Jackson
PERSONSweet
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATIONSubpoena Duces
PERSONProductions, Inc.
ORGANIZATION
Colorado
LOCATIONStatistical Tabulating Corp.
ORGANIZATION