Epstein Secrets

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-

or sexual massages .. . you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss

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-

ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss

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-

ual massages . . . [i]f you know?" had a clear meaning, and more important for purposes of the instant motion, any ambiguity was not "fundamental." Cl Triumph Capital Grp., Inc., 237 F. App'x at 628 (concluding that an answer about "this arrangement" was not fundamentally ambiguous). Nor is there any basis to dismiss