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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
1996) 20 United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 25 ii EFTA00077573 United States v. Payner, 447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v.
ts' claims of Government Franks violations. 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 v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
ts' claims of Government Franks violations. 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 v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
ts' claims of Government Franks violations. 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 v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
ts' claims of Government Franks violations. 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 v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Viliegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
ts' claims of Government Franks violations. 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 v. Delaware, 438 U.S. 154, 155-56 (1978)), that (i) there were "inaccuracies or omissions" in the
tantial preliminary showing" requirement explained above exists to "avoid fishing expeditions into affidavits that are otherwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN),
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
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 →tates v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 25 ii EFTA00028931 --- PAGE BREAK --- United States v. Payner, 447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v.
Page: EFTA00028932 →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 →United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 June 8, 2009) 25 ii EFTA00029102 --- PAGE BREAK --- United States v. Payner, 447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v.
Page: EFTA00029103 →Entities connected to both Falso and Payner

Eric Schmidt
PERSON
Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
David Boies
PERSONColleen McMahon
PERSONMartindell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Bradley Edwards
PERSONJane Doe
PERSON
Stephen Hawking
PERSONLoretta A. Preska
PERSONJeffrey Pagliuca
PERSONCanfield
PERSONthe Second Circuit's
ORGANIZATION
Supreme Court
ORGANIZATION
Carpenter
PERSONFisher
PERSONStephen Rex Brown
PERSON