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ed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Second Circuit in Brown v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protecti
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
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)
Page: EFTA00028931 →bscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Id. at 1208. Unbeknownst to Agent Stewart, Agent Second Circuit in v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protective Order's gu
Page: EFTA00028953 →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)
Page: EFTA00029102 →ed by FBI Agent Linda Stewart, which itself was based on the reports and investigation of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's Second Circuit in Brown v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protecti
Page: EFTA00029124 →Entities connected to both Martha Stewart and Falso

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
George Mitchell
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Stephen Hawking
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
Michael Jackson
PERSON
James Baker
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
David Boies
PERSON
Scarlett Johansson
PERSON
Michigan
LOCATIONFBI
ORGANIZATION