Epstein Secrets

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-

ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!

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-

ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant 36 See, e.g., hit'!

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-

ishes "some extraordinary circumstance or compelling need." Martindell, 594 F.2d at 296. After concluding that reliance on the protective order was unreasonable,36 Chief Judge McMahon found that the "Government [ ] persuasively demonstrated extraordinary circumstances," citing "significant '6 See, e.g., Intl E