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orney Alex] Acosta, [Former USAO-SDFL supervisor Andrew] Lourie, or Villafaiia agreed to the nonprosecut
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
hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di
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
hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di
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
hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di
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
hild Exploitation and Obscenity Section ("CEOS"), Andrew Oosterbaan, during the investigation and plea di
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
New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 6, 2019
Page: EFTA00016596 →sory allegation that the requested evidence is material.' United States v. Abdalla, 317 F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States v. Urena, 989 F.Supp.2d 253, 261 (S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the production of certain docume
Page: EFTA00016597 →Entities connected to both Prince Andrew and Urena

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Michael Cohen
PERSONthe Southern District
LOCATIONDarren Indyke
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
John F. Kennedy
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Geoffrey S. Berman
PERSON
Michael Jackson
PERSON