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744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v. Swanson, 210 F.3d 788, 790 (7th Cir. 2000) ("These elements are hard to prove, and thus Franks hearings are rarely held."). b. Discussion In an alternati
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept 8, 2015), afd, 730 F. App'x 25 (2d Cir. 2018) (citing
744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v. Swanson, 210 F.3d 788, 790 (7th Cir. 2000) ("These elements are hard to prove, and thus Franks hearings are rarely held."). b. Discussion In an alternati
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v. Swanson, 210 F.3d 788, 790 (7th Cir. 2000) ("These elements are hard to prove, and thus Franks hearings are rarely held."). b. Discussion In an alternati
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v. Swanson, 210 F.3d 788, 790 (7th Cir. 2000) ("These elements are hard to prove, and thus Franks hearings are rarely held."). b. Discussion In an alternati
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
744 F. Supp. 558, 567 (S.D.N.Y. 1990) ("A defendant seeking to have the Court hold a Franks hearing bears a substantial burden."); United States v. Swanson, 210 F.3d 788, 790 (7th Cir. 2000) ("These elements are hard to prove, and thus Franks hearings are rarely held."). b. Discussion In an alternati
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
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