Epstein Secrets

194 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207,214,217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), tert denied, No. 20-5064, -- S.O. -- , 2021 WL 78

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).3i AUSA-1 was not involved in

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

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cert denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).31 AUSA-1 was not involved in

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

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cert denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).31 AUSA-1 was not involved in

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

d States v. Brand, 556 F.2d 1312 (5th Cir. 1977) 52 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 139, 143, 145 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 115 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020) 26, 29 United States v. Brown, No. 07-0296, 200

articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, Even from Jail, Sex Abuser Manipulated The System. His Victims Were Kept in The Dark, Miami Herald, Nov. 28, 2018.32 AUSA-1 was not involved in the

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

94 (PKL), 2005 WL 77055 (S.D.N.Y. Jan. 12, 2005) 257 United States v. Broccolo, 797 F. Supp. 1185 (S.D.N.Y. 1992) 207, 214, 217 United States v. Brown, 744 F. Supp. 558 (S.D.N.Y. 1990) 170 United States v. Brown, 800 F. App'x 455 (9th Cir. 2020), cent denied, No. 20-5064, S.Ct. , 2021 WL 78235

f articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, "Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark," Miami Herald (Nov. 28, 2018).3' AUSA-1 was not involved in

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

-054, Zamora 176050-054 781 76/5 1:15 PM +3 I/M Brown #70786-050, Marshall #11867-087, Quiroga #86210-0

commit: Hallwood #63577-054, Latimer #79427-054 114 69/5 8:30 PM Trash run in progress 9:00 PM 2 inmates escorted from GN to IA: Rosa #86324-054, Urena A28631- 054. ( Phone charger, cable, sharpened weapon, Amephetamines 71/5 9:25 PM Trash run complete 10:00 PM Institutional count in progress. 10

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

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-

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

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-

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

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-

mental informant. Id. The burden to even obtain a Franks hearing is a heavy one, and such hearings are thus exceedingly rare. See United States v. Brown, 744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v

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-