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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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as Giuffre's personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epst
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
ly considered and approved such an outcome, or communicated such a promise to Epstein. Further still, the record in the civil case makes clear that USAO-SDFL's position was that the NPA did not bind other districts. In a July 5, 2013 brief, USAO-SDFL stated: [T]he Non-Prosecution agreement simply obligated
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
ex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At the meeting, Edwards provided AUSA-1 with details about, among other things, the USAO-SDFL's prior investigation of Epstein, as well as personal history and experience with Epstein. (See Ex. 5). The focus of the meeting was on Epstein, and
Entities connected to both Urena and USAO-SDFL's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONMartin Weinberg
PERSON
United States
LOCATIONthe Southern District
LOCATION
Scarlett Johansson
PERSONMaria Farmer
PERSON
Carpenter
PERSON
Figueroa
PERSON
Bradley Edwards
PERSON
Bill Richardson
PERSON
Julie K. Brown
PERSON
Rivera
PERSON
Michael Jackson
PERSON
Martinez
PERSON
Southern District of New York
ORGANIZATIONElstad
PERSON
Adriana Ross
PERSON
Chris Tucker
PERSON
Kendall Coffey
PERSON