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understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary 130 EFTA00095222 intelligence would not think that a question asking for inform
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
irectly rebutting the defendant's allegations, there is no material issue of fact sufficient to justify an evidentiary hearing. The defendant cites Franks v. Delaware, 438 U.S. 154 (1978), to suggest that a hearing is somehow warranted, but her motion falls far short of the Franks standard to obtain a hearing. "W
ed States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33,37,38,46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351
20 (2d Cir. 1928) 45 Fisher v. United States, 425 U.S. 391 (1976) 140, 146 Flagg v. Yonkers Sav. & Loan Assn, 396 F.3d 178 (2d Cir. 2005) 143 Franks v. Delaware, 438 U.S. 154 (1978) 166, 169, 170,171 Gatlo, 17 Cr. 686 (LAK) 275 Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991) 125 Graham v. Co
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding `rea
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (
(2d Cir. 1928) 45 Fisher v. United States, 425 U.S. 391 (1976) 140, 146 Flagg v. Yonkers Say. & Loan Ass 'n, 396 F.3d 178 (2d Cir. 2005) 143 Franks v. Delaware, 438 U.S. 154 (1978) 166, 169, 170, 171 Gatto, 17 Cr. 686 (LAK) 275 Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991) 125 Graham v. C
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding `rea
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (
(2d Cir. 1928) 45 Fisher v. United States, 425 U.S. 391 (1976) 140, 146 Flagg v. Yonkers Say. & Loan Ass 'n, 396 F.3d 178 (2d Cir. 2005) 143 Franks v. Delaware, 438 U.S. 154 (1978) 166, 169, 170, 171 Gatto, 17 Cr. 686 (LAK) 275 Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991) 125 Graham v. C
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding `rea
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jqffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351
(2d Cir. 1928) 45 Fisher v. United States, 425 U.S. 391 (1976) 140, 146 Flagg v. Yonkers Say. & Loan Ass 'n, 396 F.3d 178 (2d Cir. 2005) 143 Franks v. Delaware, 438 U.S. 154 (1978) 166, 169, 170, 171 Gatto, 17 Cr. 686 (LAK) 275 Golino v. City of New Haven, 950 F.2d 864 (2d Cir. 1991) 125 Graham v. C
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding 'rea
tain 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 affidavit, (ii) "the alleged falsehoods or omissions were nece
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