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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
ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr
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-
w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.
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
ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro
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-
w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.
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
ircuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively extend the limitations period for still-viable pro
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-
w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.
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. Leo Sure Chief, 438 F.3d 920, 922-25 (9th Cir. 2006); United States v. Jeffiies, 405 F.3d 682, 685 (8th Cir. 2005). Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr
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
rcuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief, 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactively extend the limitations period for still-viable pr
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-
w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.
Entities connected to both Urena and the Second Circuit's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Supreme Court
ORGANIZATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONMartindell
PERSON
David Boies
PERSON
Colorado
LOCATIONMartin Weinberg
PERSONFisher
PERSONJimenez
PERSON
Rivera
PERSON
Eric Schmidt
PERSON
Bronx
LOCATIONColleen McMahon
PERSONThompson
PERSON
Bill Richardson
PERSON