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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-
ttributable to the government "only when it can be said that the State is responsible for the specific conduct of which the [defendant] complains." Blum v. Yaretsky, 457 U.S. 991, 1004 (1982) (emphasis in original). "Such responsibility is normally found when the State `has exercised coercive power or has provi
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-
ttributable to the government "only when it can be said that the State is responsible for the specific conduct of which the [defendant] complains." Blum v. Yaretsky, 457 U.S. 991, 1004 (1982) (emphasis in original). "Such responsibility is normally found when the State `has exercised coercive power or has provi
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-
ttributable to the government "only when it can be said that the State is responsible for the specific conduct of which the [defendant] complains." Blum v. Yaretsky, 457 U.S. 991, 1004 (1982) (emphasis in original). "Such responsibility is normally found when the State `has exercised coercive power or has provi
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-
ttributable to the government "only when it can be said that the State is responsible for the specific conduct of which the [defendant] complains." Blum v. Yaretsky, 457 U.S. 991, 1004 (1982) (emphasis in original). "Such responsibility is normally found when the State 'has exercised coercive power or has provi
Entities connected to both Urena and Blum v. Yaretsky

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Ghislaine Maxwell
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Bill Richardson
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Julie K. Brown
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Michael Jackson
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Figueroa
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Scarlett Johansson
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Adriana Ross
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Bradley Edwards
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Chris Tucker
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Kendall Coffey
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David Boies
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