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whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
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),
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
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),
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
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),
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
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),
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
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),
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