Epstein Secrets

omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A

as recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this

omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A

as recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this

omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A

as recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this

omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A

as recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this

omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A

as recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this

d. at 538-39. "[L]ess drastic measures ... such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),

s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame

. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),

s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame

. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),

s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame

the counts would waste judicial resources by requiring a second trial at 53 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),

s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Viliegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame

d. at 538-39. "[L]ess drastic measures ... such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),

s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame