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ited States v. Shaw, 260 F. Supp. 2d 567,570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
evidentiary hearing or suppressing the evidence"). The defendant's allegations are analogous to those raised when evaluating defendants' 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
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
evidentiary hearing or suppressing the evidence"). The defendant's allegations are analogous to those raised when evaluating defendants' 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
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
evidentiary hearing or suppressing the evidence"). The defendant's allegations are analogous to those raised when evaluating defendants' 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
ed States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] 112 EFTA00095204 raised by an affidavit of a person with personal k
evidentiary hearing or suppressing the evidence."). The defendant's allegations are analogous to those raised when evaluating defendants' 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
ted States v. Shaw, 260 F. Supp. 2d 567, 570 (E.D.N.Y. 2003); see also United States v. Gillette, 383 F.2d 843, 848 (2d Cir. 1967); United States v. Ahmad, 992 F. Supp. 682, 685 (S.D.N.Y. 1998) ("ordinarily [a factual issue must be] raised by an affidavit of a person with personal knowledge of the fac
evidentiary hearing or suppressing the evidence"). The defendant's allegations are analogous to those raised when evaluating defendants' 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
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