Epstein Secrets

447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 23 Wang v. Reno, 81 F.3d 808 (9th Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities St

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Cir. 1996)

applies, Maxwell has easily met her burden. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks, 438 U.S. at 155-56), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82,91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregiou

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregio

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregio

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregiou

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregio

ts' claims of Government Franks violations. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the

tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),

could "agree" to the occurrence of a predicate pursuant to his NPA obligations but still contest that the plaintiff was injured, see United Stated, Scheidt, supra (finding each to be a separate element) and the letter from Mr. Acosta to Mr. Starr, supra December 4, 2007 letter at p.2 which agrees that

imposed minimum. Notwithstanding the above legal analysis, in the recent case of Individual Known to Defendant As 08MIST096.JPG and 08mist067.ipg Falso, 2009 WL 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York s Plaintiff has attempted to allege 6

); Doe No. 41. Epstein, 2009 WL 383286 (S.D. Ha. Feb. 12, 2009); and Doe No. 5I. Epstein, 2009 WI, 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.CaI. Jan. II, 2010)- U.S.'. Rena, 2009 WI, 2579103, fn. I (E.D. Cal. Aug. 19, 2009); U.S. Ferenci, 2009 WL

imposed minimum. Notwithstanding the above legal analysis, in the recent case of Individual Known to Defendant As 08M1ST096.JPG and 08mist067.iog Falso, 2009 WI, 4807537 (N.D. N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York Plaintiff has attempted to allege 6

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)

447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 23 Wang v. Reno, 81 F.3d 808 (9th Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities St

20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)

447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 23 Wang v. Reno, 81 F.3d 808 (9th Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities St