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or the truth." Lambus, 897 F.3d at 399. The standard to demonstrate material false statements and omissions in an agent's affidavit is a "high one." Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991). The intent prong of Franks is particularly demanding with respect to omissions. "Franks protect
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
or the truth." Lambus, 897 F.3d at 399. The standard to demonstrate material false statements and omissions in an agent's affidavit is a "high one." Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991). The intent prong of Franks is particularly demanding with respect to omissions. "Franks protect
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
or the truth." Lambus, 897 F.3d at 399. The standard to demonstrate material false statements and omissions in an agent's affidavit is a "high one." Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991). The intent prong of Franks is particularly demanding with respect to omissions. "Franks protect
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
or the truth." Lambus, 897 F.3d at 399. The standard to demonstrate material false statements and omissions in an agent's affidavit is a "high one." Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991). The intent prong of Franks is particularly demanding with respect to omissions. "Franks protect
rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim
or the truth." Lambus, 897 F.3d at 399. The standard to demonstrate material false statements and omissions in an agent's affidavit is a "high one." Rivera v. United States, 928 F.2d 592, 604 (2d Cir. 1991). The intent prong of Franks is particularly demanding with respect to omissions. "Franks protect
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
Entities connected to both Rivera and Ruiz and Broccolo

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Scarlett Johansson
PERSON
Southern District of New York
ORGANIZATION
Julie K. Brown
PERSONMaria Farmer
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Bradley Edwards
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Bill Richardson
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Michael Jackson
PERSONthe Southern District
LOCATIONMartin Weinberg
PERSONThompson
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George Mitchell
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Colorado
LOCATIONJane Doe
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Oregon
LOCATION
Supreme Court
ORGANIZATION
Anderson
PERSON
Michigan
LOCATION