Epstein Secrets

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

uary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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

ary 11, 2021, another version of the July 2016 deposition was publicly filed with fewer redactions. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1). 9. The New York Daily News Article On October 13, 2020, the New York Daily News published an article describing the February 29, 2016 meeting (the "Daily News Article" or the "Articl

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

TA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

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

TA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

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.

8 b. April ', 70 EFTA00095068 c. Chief Judge McMahon's Memorandum and Order 71 7. &OAS% 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl

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

TA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge Netbum's Order 74 8. Unsealing of Maxwell's Depositions 74 9. The New York Daily News Article 75 B. The Defendant's Suppression Motion Should Be Denied 76 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks 76 a. Appl