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ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with =attorneys. Ex. N. AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written n
20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Cir. 1996)
applies, Maxwell has easily met her burden. To obtain a Franks hearing, a defendant must make a "substantial preliminary showing," United States v. Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks, 438 U.S. at 155-56), that (i) there were "inaccuracies or omissions" in the affidavit, (ii) "the
20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)
Page: EFTA00028931 →ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with attorneys. Ex. N. AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written no
Page: EFTA00028938 →20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States v. Cortina, 630 F.2d 1207 (7th Cir. 1980) 20, 22, 25, 26 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996)
Page: EFTA00029102 →ication of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with attorneys. Ex. 1 . AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written
Page: EFTA00029109 →Entities connected to both the Public Corruption Unit and Falso

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Stephen Hawking
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
David Boies
PERSON
Adriana Ross
PERSON
Eric Schmidt
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Bill Richardson
PERSON
Chris Tucker
PERSONFBI
ORGANIZATION