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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
create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salarneh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See
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-
the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United States v. Salarneh, 152 F.3d 88, 145-46 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor
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-
the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United States v. Salarneh, 152 F.3d 88, 145-46 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor
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-
the indictment was committed by one or more of the members of the conspiracy in furtherance of the objectives of the conspiracy." United States v. Salarneh, 152 F.3d 88, 145-46 (2d Cir. 1998). Because a conspiracy does not require the completion of a substantive crime, it does not matter whether Minor
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