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ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the firstFranks hurdle with a substantial preliminary showingof a false statement or om
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "'[a]ll storytelling involves an element of selectivity,' and it is therefore not necessarily co
be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv
ns [were] the result of the affiant's deliberate falsehood or reckless disregard for the truth." Lambus, 897 F.3d at 397; see also United States v. Awadallah, 349 F.3d 42, 64 (2d Cir. 2003). Even if a defendant clears the first Franks hurdle with a substantial preliminary showing of a false statement or
o omissions. "Franks protects against omissions that are designed to mislead, or that are made in reckless disregard of whether they would mislead." Awadallah, 349 F.3d at 68 (emphasis in original). After all, "la]ll storytelling involves an element of selectivity,' and it is therefore not necessarily con
be a causal connection between the violation and the deprivation of the defendant's life or liberty threatened by the prosecution." United States v. Ghailani, 751 F. Supp. 2d 502, 505 (S.D.N.Y. 2010). "That is to say, relief against the government in a criminal case is appropriate if, and only if, a conv
United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 U
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298 U
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
United States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 100 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 88 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 113, 114 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Barlow, 732 F. Supp. 2d 1 (E.D.
United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 191 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 35, 36 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 106 United States v. Ghavami, 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 171 United State
ited States v. Ash, 464 F. Supp. 3d 621 (S.D.N.Y. 2020) 145 United States v. Ashburn, 76 F. Supp. 3d 401 (E.D.N.Y. 2014) 126 United States v. Awadallah, 349 F.3d 42 (2d Cir. 2003) 166, 168 United States v. Bahna, 68 F.3d 19 (2d Cir. 1995) passim United States v. Balde, 20 Cr. 281 (KPF) 298
222 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649 (D.N.J. 2017) 48 United States v. Ghailani, 751 F. Supp. 2d 502 (S.D.N.Y. 2010) 155 United States v. Ghavami, No. 10 Cr. 1217 (KMW), 2012 WL 2878126 (S.D.N.Y. July 13, 2012) 262 United S
Entities connected to both Awadallah and Ghailani

Jeffrey Epstein
PERSON
Ghislaine Maxwell
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United States
LOCATION
Southern District of New York
ORGANIZATIONthe Southern District
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Bradley Edwards
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Julie K. Brown
PERSONColleen McMahon
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Adriana Ross
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Michael Jackson
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Scarlett Johansson
PERSONthe Second Circuit's
ORGANIZATION
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