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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
Fifth Amendment privilege, no shield protects the civil evidence [ ] from compellable production before the grand jury which subpoenaed it"). 4. The Government Did Not Violate Maxwell's Due Process Rights The defendant also claims that the Government's conduct "cannot be squared with elemental due process." (Def. Mot. 3 a
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
Fifth Amendment privilege, no shield protects the civil evidence [ ] from compellable production before the grand jury which subpoenaed it"). 4. The Government Did Not Violate Maxwell's Due Process Rights The defendant also claims that the Government's conduct "cannot be squared with elemental due process." (Def. Mot. 3 a
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
Fifth Amendment privilege, no shield protects the civil evidence [ ] from compellable production before the grand jury which subpoenaed it"). 4. The Government Did Not Violate Maxwell's Due Process Rights The defendant also claims that the Government's conduct "cannot be squared with elemental due process." (Def. Mot. 3 a
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
Fifth Amendment privilege, no shield protects the civil evidence [ ] from compellable production before the grand jury which subpoenaed it"). 4. The Government Did Not Violate Maxwell's Due Process Rights The defendant also claims that the Government's conduct "cannot be squared with elemental due process." (Def. Mot. 3 a
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
Fifth Amendment privilege, no shield protects the civil evidence [ ] from compellable production before the grand jury which subpoenaed it"). 4. The Government Did Not Violate Maxwell's Due Process Rights The defendant also claims that the Government's conduct "cannot be squared with elemental due process." (Def. Mot. 3 a
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