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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
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
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
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
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
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
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
bstitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.'" Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
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
substitute for Fourth Amendment jurisprudence, which adequately safeguards against unlawful searches and seizures.' Lambus, 897 F.3d at 401 (quoting Ming He, 94 F.3d at 792); see also United States v. Payner, 447 U.S. 727, 737 (1980) ("the supervisory power does not extend so far" as to "confer on the j
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