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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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
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
answered the questions truthfully. A jury should be allowed to hear the questions in context to evaluate their materiality, which cannot be done at this stage.51 The Court therefore should deny the motion. In any event, the perjurious statements were material in both senses of the definition. First, the questions wer
Entities connected to both Awadallah and this stage.51 The Court

United States
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Jeffrey Epstein
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Bradley Edwards
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Ghislaine Maxwell
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New Haven
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Minnesota
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